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GAMING, RACING AND BETTING ACT
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12. Organisation
2023 Laws not yet authenticated through a Commencement Order

Revised Laws of Saint Lucia (2023)

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12.   Organisation

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    (1)   Each gaming operator shall have a system of internal control that includes the following—

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      (a)     administrative control which includes, but is not limited to, the plan of organisation and the procedures and records that are concerned with the decision processes leading to management's authorisation of transactions; and

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      (b)     accounting control which includes the plan of organisation and the procedures and records that are concerned with the safeguarding of assets and the reliability of financial records and are consequently designed to provide reasonable assurance that—

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        (i)     transactions are executed in accordance with the management's general and specific authorisation which shall include the requirements of these Regulations,

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        (ii)     transactions are recorded as necessary to permit preparation of financial statements in conformity with generally accepted accounting principles and with regulation 7, and to maintain accountability for assets,

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        (iii)     access to assets is permitted only in accordance with management's authorisation which shall include the requirements of these Regulations, and

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        (iv)     the recorded accountability for assets is compared with existing assets at reasonable intervals and appropriate action is taken with respect to any differences.

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    (2)   The gaming operator's system of internal controls shall provide for—

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      (a)     competent personnel with integrity and an understanding of prescribed procedures; and

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      (b)     the segregation of incompatible functions so that no employee is in a position to perpetrate and conceal errors or irregularities in the normal course of his or her duties.

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    (3)   Each gaming operator shall, at a minimum, establish the following departments with respect to his or her gaming establishment—

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      (a)     a Surveillance Department supervised by a Director of Surveillance who shall co-operate with and perform independently of all other departments and shall report directly to the managing authority of the gaming operator regarding matters of policy, purpose, responsibilities and authority and indirectly to the Chief Operating Officer for daily operations and the Director of Surveillance shall be responsible for the following—

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        (i)     the clandestine surveillance of the operation and conduct of the table games,

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        (ii)     the clandestine surveillance of the operation of the slot machines,

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        (iii)     the clandestine surveillance of the operation of the cashiers cage,

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        (iv)     the audio-video taping of activities in the count rooms,

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        (v)     the detection of cheating, theft, embezzlement, and other illegal activities in the gaming establishment, count rooms, change booths, and cashiers cage,

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        (vi)     the video taping of illegal and unusual activities monitored,

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        (vii)     the notification of appropriate Gaming Supervisors, and the Board upon the detection and taping of cheating, theft, embezzlement, or other illegal activities, and

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        (viii)     any other function approved by the Board;

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      (b)     an Internal Audit Department supervised by an Executive Officer who shall perform independently of all other departments and who shall report directly to the managing authority of the gaming operator regarding matters of policy, purpose, responsibilities and authority and indirectly to the Chief Operating Officer for daily operations and such department shall be responsible for the following, and any other function approved by the Board—

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        (i)     the review and appraisal of the adequacy of internal controls,

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        (ii)     the compliance with internal controls procedures,

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        (iii)     the reporting of instances of non-compliance with the system of internal controls,

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        (iv)     the reporting of any material weaknesses in the system of internal controls,

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        (v)     the recommendation of procedures to eliminate any material weaknesses in the system of internal controls;

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      (c)     a Gaming Department supervised by a Gaming Manager who shall perform independently of all other departments and shall report directly to the Chief Operating Officer and the Gaming Manager shall be responsible for the operation and conduct of the games of craps, blackjack, baccarat-chemin de fer, baccarat-punto banco, roulette, big 6, wheel of fortune, red dog, pai gow poker, let it ride poker, casino war and Caribbean stud poker;

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      (d)     a Slot Department supervised by a Slot Department Manager who shall perform independently of all other departments and shall report directly to the Chief Operating Officer and the Slot Department Manager shall be responsible for the overall operation of the Slot Department;

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      (e)     a Credit Department supervised by a Credit Manager who shall co-operate with and perform independently of all other departments and shall report directly to the Chief Operating Officer and the Credit Manager shall be responsible for the credit function including the following—

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        (i)     the verification of patron credit references,

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        (ii)     the establishment of patron credit limits,

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        (iii)     the maintenance, review and update of the patron's credit lines, and

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        (iv)     any other function approved by the Board;

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      (f)     a Security Department supervised by a Director of Security who shall co-operate with, yet perform independently of, all other departments and shall report directly to the Chief Operating Officer or his or her equivalent and the Director of Security shall be responsible for the overall security of the establishment including the following—

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        (i)     the enforcement in the establishment of all relevant laws,

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        (ii)     the physical safety of patrons in the establishment,

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        (iii)     the physical safety of personnel employed by the establishment,

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        (iv)     the physical safeguarding of assets transported to and from the Slot Department and Cashiers Cage Department,

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        (v)     the protection of the patrons and the establishment's property from illegal activity,

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        (vi)     the detainment of persons that may be involved in illegal acts for the purpose of notifying the law enforcement or the Board, and

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        (vii)     the recording of any and all unusual occurrences within the gaming establishment for which the assignment of a Security Department employee is made and each incident, without regard to materiality, shall be assigned a sequential number and, at a minimum, the following information shall be recorded in indelible ink in a bound notebook from which pages cannot be removed and each side of each page of which is sequentially numbered, the assignment number, the date, the time, the nature of the incident, the persons involved in the incident, and the Security Department employee assigned,

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        (viii)     verification of Jackpot payouts and hopper re-fills, and

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        (ix)     any other function approved by the Board;

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      (g)     an Accounts Department supervised by a Director of Gaming Accounting who shall report directly to the Chief Financial Officer and the Director of Gaming Accounting shall be responsible for the following—

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        (i)     accounting controls,

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        (ii)     the preparation and control of records and data required by these Regulations,

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        (iii)     the control of stored data, the supply of unused forms, the accounting for and comparing of forms used in operating the gaming establishment and required by these Regulations, and

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        (iv)     the control and supervision of the Cashiers Cage Department,

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      (h)     a Cashiers Cage Department supervised by a Cage Manager who shall supervise cage cashiers, slot cashiers, and change persons, and co-operate with and perform independently of the Slot Department and Security Department and shall be under the supervision of, and report directly to, the Director of Gaming Accounting and the Cashiers Cage Department shall be responsible for the following—

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        (i)     the custody of currency, coins, patrons' cheques and markers, gaming chips and gaming plaques, documents and records normally associated with the operation of a cashiers cage,

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        (ii)     the approval, exchange, redemption and consolidation of patrons' cheques and markers received for the purpose of gaming in conformity with these Regulations,

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        (iv)     the receipt, distribution and redemption of gaming chips and gaming plaques in conformity with these Regulations,

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        (v)     such other functions normally associated with the operation of a cashiers cage, and

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        (vi)     any other function approved by the Board.

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    (4)   The employees of gaming operator shall be trained in all accounting and internal control practices and procedures relevant to each employee's individual function.

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    (5)   Special instructional programs shall be developed by the gaming operator in addition to any on-the-job instruction sufficient to enable all members of the departments required by this regulation to be thoroughly conversant and knowledgeable with the appropriate and required manner of performance of all transactions relating to their function.

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    (6)   Functions described in this regulation shall be performed only by persons approved by the Board to do to the particular position.

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    (7)   A person shall not be transferred from the Surveillance Department within the same gaming establishment without the prior approval of the Board.

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2nd Floor Francis Compton Building, 
Waterfront,
Castries, Saint Lucia

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