Florida Regulations 75-14.015: Slot Machine Licensee Organizational Structure
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(1) Each slot machine licensee shall maintain an organizational structure which meets the following criteria designed to preserve the integrity of the eligible facility operation. Provided the criteria of this section are met, each slot machine licensee shall be permitted to tailor its organizational structure to meet the needs of its own particular management style. The proposed table of organization of each slot machine licensee shall be approved by the division and shall provide for the following criteria:
(a) A list identifying management and supervisory personnel holding professional occupational licenses who will be held accountable for actions or omissions within their area of responsibility; and,
(b) Supervisory positions which permit the authorization or supervision of necessary transactions at all relevant times.
(2) Each slot machine licensee shall designate a chief gaming executive. The chief gaming executive shall be the person located at the slot machine licensee’s facility who is responsible for the daily conduct of slot machine gaming including the direct or indirect supervision of the departments required by this section regardless of the slot machine licensee’s form of business association or the particular title which that person holds.
(3) In addition to satisfying the requirements of subsection (1), above, each slot machine licensee’s organizational structure shall include, at a minimum, the following mandatory departments and supervisory positions:
(a) The Accounting Department is responsible for verifying financial transactions, and reviewing and controlling accounting forms and data. The function shall include, but is not limited to, a daily audit of the slot machine gaming documentation, a daily audit of the gaming facility cage accountability, a daily audit of the vault accountability, document control and signature verification;
(b) The Cashier’s Cage is responsible for the following:
1. The custody of coin, currency, documents, and records associated with the operation of a cashier’s cage,
2. The receipt, distribution, and redemption of any tickets and vouchers; and,
3. The segregation of funds related to slot machine activity from funds related to pari-mutuel activity,
(c) The Surveillance Department shall be independent of all aspects of gaming facility operations and shall be supervised by a gaming facility employee holding a professional occupational license assigned the position of Director of Surveillance. The Director of Surveillance shall report to the slot machine licensee, or to a corporate executive outside the immediate property management team, or to another independent reporting line. The Surveillance Department is responsible for the covert monitoring of:
1. The conduct and operation of slot machines,
2. The conduct and operation of the cashier’s cage,
3. The collection and count of the slot drop,
4. The movement of any cash storage box within the facility, any bills, tickets, or vouchers removed from a slot machine, or the movement of cash while being transported to a count room or armored car bay,
5. Detection and recording of cheating, theft, embezzlement, and other illegal activities in the gaming facility; and,
6. Detection of the presence in the gaming facility of any person who is required to be excluded pursuant to voluntary and involuntary exclusions,
(d) The Security Department is responsible for the overall security of the facility including the following:
1. The physical safety of patrons and employees in the slot machine licensee’s facility,
2. The physical safeguarding of assets, with the exception of slot machines whose cash boxes have been removed and are under active surveillance, transported to, from, or through the facility,
3. The protection of patrons, employees and gaming facility property from illegal activity,
4. The detainment of individuals when there is probable cause to believe that they are in violation of the law or gaming regulations,
5. The recordation of any and all suspicious activity including the date, time, nature of the incident, persons involved in the incident, and the assigned Security Department personnel; and,
6. The identification and removal of any person who is required to be excluded pursuant to voluntary or involuntary exclusion requirements,
(e) The Slot Department is responsible for all aspects of the operation of the slot machines and shall be supervised by a management-level employee manager or assistant manager;
(f) The Internal Audit Function of a slot machine licensee shall be through a separate or through outsourcing of this function. The Internal Audit Function shall be responsible for the following:
1. Reviewing and appraising the adequacy of internal controls,
2. Ensuring compliance with internal controls through observations and review of accounting documentation,
3. Reporting instances of non-compliance with the system of internal controls,
4. Reporting of any material weaknesses in the system of internal controls disclosed by an audit conducted under generally accepted accounting principles,
5. Recommending improvements in the system of internal controls,
6. Creating audit reports that shall include the following information:
a. Audit objectives,
b. Audit procedures and scope,
c. Findings and conclusions,
d. Recommendations, if applicable; and,
e. Management’s response; and,
7. Internal audit findings shall be reported to management. Management shall be required to respond to internal audit findings stating corrective measures to be taken to avoid recurrence of the audit exception. Such management responses shall be included in the internal audit report that shall be delivered to management, the audit committee, the division upon request, or any other entity designated by the slot machine licensee; and,
(g) The Management Information Systems (MIS) Department is responsible for the quality, reliability, and accuracy of all computer systems used in the operation and shall be responsible for and maintenance of:
1. Access codes and other data-related security controls used to ensure authorized access to computers and the system-wide reliability of data,
2. Computer tapes, disks, or other electronic storage media containing data relevant to gaming facility operations; and,
3. Computer hardware, communications equipment and software used in the conduct of gaming facility operations.
(4) No person shall be assigned to duties that would enable the person to perpetrate an error or commit fraud and conceal evidence of the error or fraud in the course of their duties.
(5) The slot machine licensee shall designate a custodian of records for each department referenced in subsection (3). The slot machine licensee shall provide a written notification to the division listing the custodian of records for each department. The slot machine licensee shall update the list whenever the employee designated as the custodian of records is changed.
Rulemaking Authority 551.103(1), 551.122 FS. Law Implemented 551.103(1)(a), (b), (d), (e), (i) FS. History-New 6-25-06, Amended 5-30-17, Formerly 61D-14.015.
Terms Used In Florida Regulations 75-14.015
- Assets: (1) The property comprising the estate of a deceased person, or (2) the property in a trust account.
- Embezzlement: In most states, embezzlement is defined as theft/larceny of assets (money or property) by a person in a position of trust or responsibility over those assets. Embezzlement typically occurs in the employment and corporate settings. Source: OCC
- Evidence: Information presented in testimony or in documents that is used to persuade the fact finder (judge or jury) to decide the case for one side or the other.
- Fraud: Intentional deception resulting in injury to another.
- Probable cause: A reasonable ground for belief that the offender violated a specific law.
(b) Supervisory positions which permit the authorization or supervision of necessary transactions at all relevant times.
(2) Each slot machine licensee shall designate a chief gaming executive. The chief gaming executive shall be the person located at the slot machine licensee’s facility who is responsible for the daily conduct of slot machine gaming including the direct or indirect supervision of the departments required by this section regardless of the slot machine licensee’s form of business association or the particular title which that person holds.
(3) In addition to satisfying the requirements of subsection (1), above, each slot machine licensee’s organizational structure shall include, at a minimum, the following mandatory departments and supervisory positions:
(a) The Accounting Department is responsible for verifying financial transactions, and reviewing and controlling accounting forms and data. The function shall include, but is not limited to, a daily audit of the slot machine gaming documentation, a daily audit of the gaming facility cage accountability, a daily audit of the vault accountability, document control and signature verification;
(b) The Cashier’s Cage is responsible for the following:
1. The custody of coin, currency, documents, and records associated with the operation of a cashier’s cage,
2. The receipt, distribution, and redemption of any tickets and vouchers; and,
3. The segregation of funds related to slot machine activity from funds related to pari-mutuel activity,
(c) The Surveillance Department shall be independent of all aspects of gaming facility operations and shall be supervised by a gaming facility employee holding a professional occupational license assigned the position of Director of Surveillance. The Director of Surveillance shall report to the slot machine licensee, or to a corporate executive outside the immediate property management team, or to another independent reporting line. The Surveillance Department is responsible for the covert monitoring of:
1. The conduct and operation of slot machines,
2. The conduct and operation of the cashier’s cage,
3. The collection and count of the slot drop,
4. The movement of any cash storage box within the facility, any bills, tickets, or vouchers removed from a slot machine, or the movement of cash while being transported to a count room or armored car bay,
5. Detection and recording of cheating, theft, embezzlement, and other illegal activities in the gaming facility; and,
6. Detection of the presence in the gaming facility of any person who is required to be excluded pursuant to voluntary and involuntary exclusions,
(d) The Security Department is responsible for the overall security of the facility including the following:
1. The physical safety of patrons and employees in the slot machine licensee’s facility,
2. The physical safeguarding of assets, with the exception of slot machines whose cash boxes have been removed and are under active surveillance, transported to, from, or through the facility,
3. The protection of patrons, employees and gaming facility property from illegal activity,
4. The detainment of individuals when there is probable cause to believe that they are in violation of the law or gaming regulations,
5. The recordation of any and all suspicious activity including the date, time, nature of the incident, persons involved in the incident, and the assigned Security Department personnel; and,
6. The identification and removal of any person who is required to be excluded pursuant to voluntary or involuntary exclusion requirements,
(e) The Slot Department is responsible for all aspects of the operation of the slot machines and shall be supervised by a management-level employee manager or assistant manager;
(f) The Internal Audit Function of a slot machine licensee shall be through a separate or through outsourcing of this function. The Internal Audit Function shall be responsible for the following:
1. Reviewing and appraising the adequacy of internal controls,
2. Ensuring compliance with internal controls through observations and review of accounting documentation,
3. Reporting instances of non-compliance with the system of internal controls,
4. Reporting of any material weaknesses in the system of internal controls disclosed by an audit conducted under generally accepted accounting principles,
5. Recommending improvements in the system of internal controls,
6. Creating audit reports that shall include the following information:
a. Audit objectives,
b. Audit procedures and scope,
c. Findings and conclusions,
d. Recommendations, if applicable; and,
e. Management’s response; and,
7. Internal audit findings shall be reported to management. Management shall be required to respond to internal audit findings stating corrective measures to be taken to avoid recurrence of the audit exception. Such management responses shall be included in the internal audit report that shall be delivered to management, the audit committee, the division upon request, or any other entity designated by the slot machine licensee; and,
(g) The Management Information Systems (MIS) Department is responsible for the quality, reliability, and accuracy of all computer systems used in the operation and shall be responsible for and maintenance of:
1. Access codes and other data-related security controls used to ensure authorized access to computers and the system-wide reliability of data,
2. Computer tapes, disks, or other electronic storage media containing data relevant to gaming facility operations; and,
3. Computer hardware, communications equipment and software used in the conduct of gaming facility operations.
(4) No person shall be assigned to duties that would enable the person to perpetrate an error or commit fraud and conceal evidence of the error or fraud in the course of their duties.
(5) The slot machine licensee shall designate a custodian of records for each department referenced in subsection (3). The slot machine licensee shall provide a written notification to the division listing the custodian of records for each department. The slot machine licensee shall update the list whenever the employee designated as the custodian of records is changed.
Rulemaking Authority 551.103(1), 551.122 FS. Law Implemented 551.103(1)(a), (b), (d), (e), (i) FS. History-New 6-25-06, Amended 5-30-17, Formerly 61D-14.015.