The Importance of Internal Investigations
April 2008

The decision to begin a gaming investigation is an important one. In fact, it may be critical to keeping a gaming company’s most valuable asset: its gaming license. Efforts to discover potential compliance violations and the timing and diligence of subsequent investigations can show regulators and others that the gaming licensee can effectively identify and respond to allegations of wrongdoing. More importantly, a thorough and objective investigation shows the gaming enterprise’s commitment to comply with all governing laws and regulations. Together, a proactive issue discovery process and the prompt, objective and comprehensive investigation of compliance issues demonstrate that the gaming company can self-regulate without undue outside intervention.

Issue Discovery

The process used to discover potential compliance violations is an important part of a credible and effective compliance program. A gaming enterprise must establish methods and procedures, and provide the necessary resources to actively seek information about potential problems. This is best accomplished through a clear set of written and communicated polices that define acceptable behavior and practices.

Whistleblower complaints are a common way to find potential fraud or to become aware of compliance violations. Regulators and stakeholders expect that gaming companies establish and maintain a system to effectively receive and deal with whistleblower complaints. Creating a process designed to properly receive and screen complaints, analyze claims, investigate and resolve any issues, report the results, and retain essential documents is the best way to handle whistleblower complaints.

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