Career opportunities in gaming enforcement and investigation

Gambling is an attractive entertainment option for some, but it can also be a hotbed for money laundering, organized crime and other illicit activity. That means, of course, job opportunities for CFEs in a growing field. Can CFEs help deter bad actors from defrauding gaming operations? What are the potential work areas for CFEs? We’ll discuss various positions available in government agencies that are responsible for regulation, investigation and oversight of gaming and casinos.

A Federal Reserve Bank of St. Louis report shows that bettors wagered $370 billion in 2000 alone. With so much money at stake, it’s easy to see how the gaming enforcement and investigation field can present significant career opportunities.

The economic impact isn’t isolated: Between 2013 and 2015, the Michigan Gaming Control Board received more than 580 anonymous tips regarding violations of gaming laws and regulations, according to the board’s 2015 annual report. Criminals and fraudsters continually attempt to use gaming as a venue for various types of illicit activity.

The casino and gaming industry in the U.S. (and its accompanying jobs) now isn’t centered just in Las Vegas and Atlantic City. Legal gambling — including casinos, slot machines, video poker and charitable gaming — is in a growing list of U.S. states and nations.

Mission of agencies

Because of the historical nature of the influence of illegal activity (primarily organized crime) in the operations of legal gaming, government seeks to ensure the proper oversight and licensing of persons and companies entering and working in the business. Because the primary statutes authorizing gaming are state laws, government agencies hire investigators, examiners, auditors and enforcement officers to oversee gamers’ operations, finances and conduct to hopefully increase the likelihood of prevention or detection of illicit activity.

Licensing and application review

Licensing officers and background investigators are frequently the “gatekeepers” for casinos to ensure that applicants are suitable for employment. They conduct in-depth reviews of the personal and financial histories of job applicants and the entities they worked for.

Investigators scrutinize applicants’ financial standings and review bank statements, tax returns and other financial information. They might also review filings of publicly traded corporations, including federal securities filings and other data. Because of global entities’ increased involvement in domestic gaming, agents might also need to conduct intensive investigations of foreign applicants and their financial affairs.

Casino operations and floor management

Enforcement investigators or agents — typically stationed at or near casino facilities — respond quickly to incidents affecting the gaming agency’s regulations or state laws. They can also maintain extensive lists of “excluded parties” who aren’t eligible to be in gaming facilities because of criminal violations, arrests, convictions or regulatory infractions. They can also prevent entry to problem gamblers who have opted to “self-exclude” to help control their addictions.

Gaming agents work closely with casinos’ security departments to identify and investigate cheaters and con men. Using casinos’ video surveillance systems (their “eyes in the sky”), agents can track and monitor known and suspected individuals who might be cheating the games. They also look for co-opted casino employees and dealers who’ve been assisting with cheating schemes.

(To read more about casino operations and floor management, see You Gotta’ Know When to Hold ’Em … Behind Bars.)

Financial analysis and audit

Gaming is all about the money, so it’s no surprise that enforcement and investigation departments rely in large part on the work of auditors and financial examiners. Their duties include conducting surprise audits and random cash counts to ensure sufficient funds are on hand, analyzing financial statements and reports submitted to the agency to monitor a casino’s continuing financial viability, and testing internal control procedures for compliance with regulations.

Auditors can also perform systematic financial reviews to routinely monitor the performance of all games and gaming activity. Because a game’s substandard performance can be an indication of cheating, agents can conduct further testing and investigation. Auditors frequently employ interviewing techniques to ensure compliance with regulations, policies, procedures and internal controls. In short, these units use many of the skills that CFEs have attained from their ACFE training and experience.

Technical and forensics

Technical and forensic information technology positions abound. For example, the Michigan Gaming Control Board has a section called the Gaming Laboratory specifically devoted to equipment testing. Lab technicians can ensure gaming products’ integrity by providing technical expertise plus product evaluation and verification.

A similar group in New Jersey, working under the Division of Gaming Enforcement’s Technical Services Bureau (TSB), conducts initial reviews, approvals and field inspections of the slot machines located in Atlantic City hotels and casinos. Its website notes that it employs a variety of skilled professionals.

To meet demand, the TSB employs highly skilled engineers, statisticians and computer scientists who thoroughly understand electronics, math and programming, and can quickly adapt to changing technology. Forensic IT and digital reviews are critical to the future of gaming regulation.

Illegal gambling investigations

Most illicit gambling operations are unlicensed and operate underground and unregulated, and aren’t in compliance with laws. These include illicit sports wagering, bookmaking or other gambling operations, many of which are run out of bars, taverns or even homes. Detectives who typically handle these investigations come from local police department vice or narcotics units and use many of the same skills as their state counterparts in tracking money, identifying enterprises and examining records.

CFEs interested in investigating these types of cases can work with prosecutors’ offices, law enforcement agencies and other local regulatory bodies. But you don’t need to be a sworn police officer to participate; many agencies look for volunteers to assist in analysis of financial documents, accounts and even technical data recovery. They would welcome CFEs’ talents, expertise and skill sets. It’s also a great way to give back to the community and provide a public service while gaining valuable experience.

Where the jobs are

According to a 2016 report by the Rockefeller Institute and the State University of New York, only Hawaii and Utah don’t have some form of legal gaming in their states. Forty-four states offer or participate in a lottery. Nineteen states have full casino operations, while a number offer more limited video poker or slot machines at various locations.

State regulatory agencies largely control gaming. In Nevada, for example, the Nevada Gaming Control Board covers all gaming and has police and regulatory powers.

A few states (mostly those with limited forms of gaming) regulate gaming through their state police agencies. Other states use hybrid regulatory licensing agencies with criminal investigators detailed from other agencies — usually the state police (as in New Jersey).

In some states (such as Colorado), the state regulator is a policy-making body, but its operations are vested in tax or revenue agencies. Sometimes, casino regulators and pari-mutuel or horse-racing regulators are separated from each other, such as Indiana, which has the Indiana Gaming Commission and the Indiana Horse Racing Commission. In most states, stand-alone agencies run lottery operations. Find lists of lottery commissions or agencies at the National Association of State and Provincial Lotteries.

Regardless of which agency runs what, you’ll find many job opportunities as an auditor, investigator or other professional staff member. If an agency doesn’t have any current vacancies, consider looking at vendors or contractors that might have agency contracts or conduct independent audits for regulatory compliance. Regional accounting firms and even some Big 4 firms might be engaged in audits of casinos or gaming establishments. Also, joining a casino’s security or audit department might be a good way to get in the door and learn about the industry.

The North American Gaming Regulators Association has an excellent website with links to many of the offices and agencies that conduct investigations, reviews, examinations, audits and oversight of casinos, gambling establishments and charitable gaming activities. The International Association of Gaming Regulators’ website has much information on worldwide gaming regulation and oversight.

Finally, don’t forget that many Native American tribes have their own casino operations, which the National Indian Gaming Commission (NIGC) — an independent federal agency supported by the U.S. Department of the Interior — primarily regulates. Native American gaming includes 486 locations in 29 states. The NIGC has a list of member tribes on its website. Note that in some positions, tribal membership might be required.

The NIGC’s seven regional field offices oversee cooperative work with the tribes and tribal commissions running gaming establishments. The NIGC also trains and provides technical assistance in:

• Execution of statutes authorizing Native American gaming.
• Promulgation of Native American gaming regulations.
• Conducting regulatory oversight, background checks and processing of fingerprint cards for applicants.
• Audits and investigations potentially resulting in penalties or even closures of facilities.

Click here to find NIGC positions.

They have the work; you have the skills

Casino or racetrack gambling isn’t the first choice for entertainment for some. But working in these settings could be a unique and interesting career avenue. The gaming industry plus government agencies and regulators need the specialized skills that CFEs possess. The challenges posed by preventing, detecting and investigating potential fraud and theft from multiple actors present excellent opportunities for CFEs.

Colin May, CFE, a former U.S. special agent, is a federal forensic auditor (the views in “Starting Out” are his own) in Indianapolis, Indiana. He’s also an adjunct instructor of forensic studies at Stevenson University. His email address is: cmay3231@stevenson.edu.