General Key Controls

General Key Controls. Every licensee’s written System of Internal Controls shall include procedures that, at a minimum, require the following: (a) No one employee can have access to more than one key to a dual key lock box. (b) Employees having control over a key which accesses a sensitive or restricted key lock box must maintain control over their key at all times. (c) Non-gaming keys must be maintained in a separate key lock box. The licensee is prohibited from commingling sensitive (dual access) keys with non-gaming keys. (d) Errors on key control documents must be lined through. Two gaming employees involved in the gaming transaction must initial with their legible unique identification number verifying the correction. (e) All count room keys, count room key box key(s), table games and card games drop box storage rack keys, currency acceptor storage rack keys, table games and card games drop box release keys, currency acceptor door keys, table games and card games drop box contents keys, currency acceptor contents keys, and any duplicate keys are to be controlled in such a way that access to the full or empty table games and card games drop boxes, currency acceptor boxes, or to the count rooms requires at least two (2) employees representing different departments and segregated functions. If the licensee maintains a key box in the count room that contains keys required to perform the count of gaming revenues, the Count Team Manager, Count Team Supervisor or Count Team Lead and Security are required to be present to check out the key to the count room door and key(s) to the count room key box. If the licensee maintains the keys required to count gaming revenues in a manual or automated key box, documentation must be completed to evidence that two count team members are present when the keys are issued and returned for the count of the gaming revenues. The count team member(s) must accompany these keys until the time of their return. (f) If access to the table games and card games drop box release keys, currency acceptor door keys, table games and card games drop box content keys, currency acceptor content keys at other than scheduled drop and count times is required, two employees from separate departments with segregated functions, one of which must be a member of management, must be present at the time the key(s) are issued. All are required to accompany the keys until the time of their return. This access includes, but is not limited to, emergency drops, patron disputes, etc. Surveillance shall be notified prior to the removal of the drop box from the table game and card game, currency acceptor box from the slot machine and Surveillance shall monitor and record the entire process. Surveillance shall record in a log or journal all such access, and the table game number, card game number or slot machine number, as well as any unusual activity noted. If the licensee determines an emergency drop of the table game, card game, currency acceptor box is necessary, a secondary written notification to the Commission is required, pursuant to Mississippi Gaming Commission Regulation Part 9, Rule 9.2. All such access shall be documented on the key control log. At a minimum, such documentation must include the date (month, day and year), time, reason for access, table game, card game or slot machine number, printed name and signature of the participating employees. (Adopted: 12/20/2007.)