“Casino Openings” – By Richard H. Williamson, BMM SVP Regulatory Education
In many jurisdictions a casino opening includes not only the casino itself but also restaurants and often a hotel. Opening a new restaurant and a hotel are challenging in their own right but they have no comparison to the rigors of opening a casino.
As a gaming regulator for over two decades, I have been intimately involved in about a dozen casino openings and many major casino expansions which also have stress levels similarly associated with casino openings. All industries have certain rules with which to comply, e.g., building and health codes, but gambling is unique. Stemming from a beginning that historically involved organized crime figures, gambling has been permitted to flourish in the United States by being harnessed with the implementation of strict licensing and operational controls to eliminate or prevent any criminal element from the casino operations as well as from the ancillary industries.
The unique challenges of casino openings stem from the overlay of these strict regulatory rules that govern every element of gaming operations. This meticulous oversight begins long before any of the equipment arrives at the new facility. As a rule, gambling is illegal in every state except where there exists statutory adoptions by which very specific conditions are described for the governance of gambling. In jurisdictions with legalized gambling, the regulations address every aspect of establishing and operating a gambling facility beginning with licensing the operators and casino service industry companies, ending with mandated audits of the gaming operation, and overseeing every operational phase in between. It is a massive undertaking by both regulators and operators with potentially serious consequences for non-compliance. Over the years, I have seen employees implode under the stress of pre-opening activities and make critical life-changing mistakes, some of which resulted in permanent bans from the industry.
The physical facility of a casino has to be approved to ensure that it possesses the accumulation of features found to represent best practices in the casino industry and which have been documented as minimum regulatory expectations for a casino design. These approvals begin with blueprint reviews long before a shovel is put in the ground. These physical property design reviews do not involve the ambiance of the casino but rather what you would call the “back of the house” features. For example, casinos have armored car areas that are physically secured and have surveillance cameras to prevent robberies when money is being moved to or from a casino. Likewise, when money is moved within the building to or from the casino cashier cage and the armored car bay, the hallways and elevators dedicated for that task are secured and equipped with surveillance cameras. Glamorized in Oceans 11, the controls over the actual cash are elaborate albeit not as extravagant as was depicted by Hollywood.
A key component to casino controls is the concept of the segregation of duties. The idea is that no one performs a task that could result in a fraudulent activity without that task being verified within a ‘reasonable’ time frame. The reasonable time frame, of course, represents the level of risk adopted by the regulators. An example of physical controls that are deemed essential to security of both cash and cashiers involve a segregation of duties to access the cashier area as well as the controls necessary to safely permit commercial transactions between patrons and cashier personnel.
Access to the cashier cage is typically through a “man trap” which consists an area with doors at either end that are controlled by separate departments. This design is intended to prevent someone from accessing the inside of the cashier cage by overpowering the controls of the access doors. The exterior door is generally accessible from the casino floor and is controlled by the security department. The interior door is controlled by casino cage personnel. Thus, if someone overpowers security and opens the door to the mantrap, they become trapped and will be under surveillance.
Do you ever wonder why the term cage is used? The grillwork between the patron and the cashiers makes the cashier area essentially a cage. Not only does the grill prevent physical access to the cage area but, in addition, it is generally designed to enable surveillance to obtain a clear facial shot of a would-be robber or counterfeiter. There are many such facility design requirements that cumulatively create a safe and secure environment where there is a lot of cash. As an example of the need for these controls, a typical bank teller cash drawer can be impressed with $10,000.00 whereas a casino cashier of a large casino could have $100,000.00. Being a cash business, the casino needs to have enough ‘coin of the realm’ available to pay big winners on-the-spot. After all, the reason why are people attracted to a casino is the opportunity to access new found cash through their perceived skill and lady luck. Some patrons, however, want to change their odds at the casino by invoking a different withdraw strategy hence the need for physical controls to protect the property’s assets and personnel.
In the second installment of A Casino Opening, I will address the necessary preparations for the seven essential departments of a casino; accounting, operations, cashier cage, security, surveillance, IT and internal audit.