The Eyes Have It: Surveillance and Compliance in Modern Casinos

## Deconstructing Security Measures in Physical Casinos

Safeguarding brick-and-mortar casinos extends far beyond haphazardly positioned surveillance equipment. This is paramount considering the spectrum of threats these venues encounter today, ranging from active assailant incidents to credit card scams.

During the recent Global Gaming Expo (G2E) held in Las Vegas, a group of specialists, including Honoria Hebert, Director of Regulatory Adherence at Lake Charles Casino Resort, and Derk Boss, a security and observation advisor, shared their perspectives on the most urgent challenges confronting the sector. *Casino Life & Business* publication met with them and other authorities for a dialogue facilitated by Darrin Hoke.

A pivotal inquiry raised by Hoke was: “In what areas have you observed surveillance aiding compliance, and the other way around?”

Hebert underscored the vital function surveillance performs in adhering to Title 31, the anti-money laundering legislation, and submitting Suspicious Activity Reports (SARs). She highlighted a substantial transformation in recent times: “Just a handful of years ago, Title 31 revolved around documentation—surveillance was the last to be informed. It has undergone a complete reversal since then—documentation is now merely a minor aspect.”

When I submit three or four reports about questionable behavior annually, and a visitor arrives, I can contact my security staff and inquire, ‘Could you provide me with additional information? Are my suspicions justified? What do you believe their intentions are?’ I prefer not to involve them immediately since documentation is my responsibility, not theirs, but I can share patterns. Conversely, they can furnish me with data and camera footage, which has aided us in solving some major incidents.”

DB:

“We are no longer operating in the dark. We are actively examining gaming statistics, food and beverage logs, and evaluating existing protocols—gathering insights from regulatory compliance. Therefore, our approach is not arbitrary, and we do not require everyone to constantly monitor cameras for suspicious activity. It’s encouraging to witness this progression where we are utilizing departments such as compliance to assist us in fulfilling our duties.”

What are your thoughts on the role of “Customer Due Diligence” in this context, and how do you envision its impact on security and surveillance practices in the years to come?

HH:

“It’s intriguing—it seems like every month I need to deepen my understanding of our clientele. In the past, you only truly knew your customer if you received a federal grand jury summons for them or saw them featured in news reports, but now the expectation is that we should possess this knowledge before reaching that stage.”

I truly began to comprehend the significance of safety and observation when I had to perform background checks on certain individuals and thoroughly investigate their histories. Some folks might favor dealing primarily in cash, making observation and safety my ‘vision.’ I’ll examine documents, evaluate trends, perhaps even utilize Google, but observation can reveal if this individual has a gambling issue and explain their wealth. Are there questionable credit card spending habits with inflated wagering sums that give the impression of heightened activity? Can they illuminate the person’s social network? Observation has provided me with numerous insights.

DB:

Regarding observation, we possess knowledge of these gamblers – it’s our advantage. Naturally, we conduct extensive background checks on players discreetly – their identities, origins. I recall this one young man, aged 22. He frequented the craps table daily, winning and losing thousands. He drove a dilapidated vehicle, raising questions about his financial source. We investigated him and discovered he was employed at a carwash, suggesting either substantial tips or alternative dealings. As expected, it transpired he was engaged in drug trafficking or something similar. In the past, such funds would have simply surfaced at the tables without raising concerns. Nowadays, one cannot afford to ignore such matters.

Management may not prioritize firearm incidents, but it’s our responsibility to bring it to their attention. Perhaps presenting them with visual documentation of past events would be impactful. We must make them comprehend the gravity of the situation, Derk.

Derk, what is your perspective on incidents involving active assailants? How should security personnel address this issue? What function does monitoring technology serve in these situations? How can we effectively convey to leadership the urgency of this matter in today’s environment?

**DB:** Active assailant scenarios are undeniably a cause for concern – in fact, we’ve already experienced one such incident. The likelihood of a recurrence is high, given the potential for notoriety and recognition, particularly in an environment with extensive camera coverage. This is an ongoing pattern that demands our attention.

However, I haven’t observed adequate training or preparedness among personnel to effectively manage these situations. While a select few may have established protocols or strategies for response, evacuation, and coordination, these measures are not widespread, nor have they been adequately practiced. A comprehensive understanding of the necessary actions is crucial, and we simply lack sufficient practice in this area.

The security and surveillance sector must take a proactive stance and emphasize the reality of this threat and the importance of regular drills. It is imperative to ensure the readiness of security and surveillance teams, regardless of broader organizational buy-in. They are uniquely positioned to provide law enforcement with real-time information, including situational updates, locations, evacuation routes, and potential hazards.

I believed it prudent to educate new personnel on managing these circumstances. Initially, there was resistance during implementation – leadership hesitated to instill fear in employees or even introduce the concept. However, the staff appreciated the knowledge, feeling empowered with guidance on appropriate actions.

I comprehend executives’ reluctance to dwell on such events, yet it’s our duty to enlighten them – to emphasize the significance. Perhaps presenting the footage from the recent incident could be impactful. I acknowledge its disturbing nature, but comprehension is crucial.

Contingency plans are essential, but experience has taught me they often remain neglected until it’s too late.

By the 25th of October, all company devices must possess the capability to read the integrated chip within the cards. What is your perspective on PCI adherence? How do you perceive its connection to observation and safety measures?
HH:
PCI conformity necessitates elevated standards. We engage in extensive retrospective analysis, retrieving records of credit card deception – highlighting the importance of collaboration between security and surveillance. I can request past recordings from surveillance to potentially identify individuals who utilized those credit cards.

Through careful observation, we gain valuable insights into our target’s appearance and behavior. This allows us to retrace their steps, determining a potential timeframe for their hotel arrival. Should a rotating entrance or registration log exist, we increase our chances of identifying the individual, particularly if robust security measures were in place.

Its vital that your income monitoring, internal regulation, and cashier teams are always informed when credit card scams are detected. Unfortunately, this isn’t always the practice. Some patrons might dismiss small sums, stating, “My card was illicitly charged, but it wasn’t a significant amount.” However, these seemingly insignificant events might be the sole warning sign you receive. Internal review might address it, observation might be unaware, and protection might be completely uninvolved. The account might never even be marked, and a golden chance to apprehend a perpetrator could be lost.

Let’s discuss anomalies and how they relate to some larger situations.

HH:

Gaming establishments typically examine their divisions for transaction discrepancies, but these documents can be daunting. My general manager informed me he obtained over 15,000 anomaly documents in merely nine months! How do you filter through that much static to locate the genuine problems?

Conversely, we’ve encountered fraudulent activities where these anomaly documents were crucial in tracing the financial path. We had a gaming establishment supervisor who was stealing funds by simulating slot machine errors and then handling “winnings” to himself, varying from $40 to $200 per instance.

She received error notices on these matters practically every day, and the same individuals consistently approved them. Is it reasonable to fault someone when there are 15,000 deviations?

Our current objective – and we are progressing due to some highly fruitful inquiries – is to actually extract patterns from those deviation reports. You ought to inquire with your revenue protection, inspection, and regulatory teams about which personnel have the highest number of deviations and search for particular deviation categories. Once you delve in, you’ll uncover some startling information – evidence of theft that was never disclosed to Loss Prevention or security.

If you aren’t already receiving an examination of your deviation reports, insist on it. Subsequently, if you apprehend a staff member engaged in illicit activities, have your compliance team retrieve all of that person’s deviations as it will bolster your case. In certain instances, you can utilize deviation reports to determine a precise monetary sum and elevate a case from a minor offense to a felony. The data exists, you simply need to ensure it reaches you.

DB:
While they can conceal the act of stealing, they cannot hide the outcome – the funds are missing. As long as it transpired, there’s a trail – you can uncover it that way. Now, all that remains is to employ this knowledge. With a specific objective in sight, you can eliminate it swiftly and decisively.

This piece was initially published in November 2015.

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