[Final Audit Report, Controls Over Video Lottery Terminal Operations, Government of the Virgin Islands (No. V-IN-VIS-0004-2005)]
[From the U.S. Government Printing Office, www.gpo.gov]

Title: ï¿½ï¿½ï¿½



Date:  June 8, 2007


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This file contains an ASCII representation of an OIG report.  No attempt has been made to display graphic images or illustrations.  Some tables may be included, but may not resemble those in the printed version.  A printed copy of this report may be obtained by referring to the PDF file or by calling the Office of Inspector General, Division of Operations Support, at (703) 487-5443.
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This report contained information that was redacted pursuant to 5 U.S.C. ï¿½ 552(b)(2) of the Freedom of Information Act.


United States Department of the Interior
Office of Inspector General
Western Region
Federal Building
2800 Cottage Way, Suite E-2712
Sacramento, California 95825


AUDIT REPORT


Honorable John P. de Jongh, Jr.
Governor of the Virgin Islands
No. 21 Kongens Gade
Charlotte Amalie, VI  00802

Re:  Final Audit Report, Controls Over Video Lottery Terminal Operations, Government
     of the Virgin Islands (No. V-IN-VIS-0004-2005)

Dear Governor de Jongh:


The enclosed report presents the results of our audit of controls over video lottery terminals (VLT) by the Virgin Islands Lottery (Lottery).  Our objective was to determine whether the Lottery had an adequate level of control over VLT operations on the islands of St.ï¿½Thomas and St. John.  


We were troubled to find that the Lottery has virtually no control over VLT operations, a condition that raises serious concerns about whether your Government is receiving all the VLT-related revenues and taxes to which it is entitled.  Our audit, which covered calendar years 2003 through 2005, revealed that the Lottery received $8.3ï¿½million in revenues during this period.  We believe, however, that unrealized revenues may be in the millions.  We were unable to determine the exact amount of these revenues because the Lottery failed to obtain and maintain the financial documents necessary to make such a determination.  Identified monetary impacts are shown in Appendix 1.  


We noted that increasing revenues to the Government was a primary motivation for allowing video gaming on St. Thomas and St. John.  VLTs were expected to generate additional revenues to the Government of about $15ï¿½million annually, thereby enabling the Government to implement or supplement programs to improve the economy and quality of life for the people of the Virgin Islands.  The Lottery, however, could not verify the actual revenues generated from VLTs and has not acted to collect the Governmentï¿½s share of these revenues.  Instead, Southland Gaming of the Virgin Islands (SGVI) controls every aspect of video gaming on the islands as a result of (1) a flawed contract and master license agreement that did not protect the Governmentï¿½s interests and (2) the failure of the Lottery to oversee VLT operations and retailer accounts.


The lack of Lottery oversight is evidenced by the absence of standard gaming protocols at nearly every level of VLT operations, from equipment installation and testing to revenue collection.  For example, the Lottery does not participate in or monitor either the downloads by SGVI of data from VLTs on the amount of cash gambled and won by customers or the distribution of net VLT revenues among the Lottery, SGVI, and retailers.  Without a verification protocol, the Lottery must accept at face value the revenue data presented by SGVI.  In contrast, a gaming protocol instituted by New Jersey mandates that representatives of both the casino and the casino control commission be present to verify that gaming receipts are accurately and completely accounted for and not improperly removed from machines.  All gaming machines have a double-locked compartment, with one key controlled by the casino and a second key controlled by the casino control commission.  


Standard gaming protocols provide a system of checks and balances to protect gaming from fraud and abuse of gaming revenues.  The lack of such a system for VLT operations not only compromises the integrity of these operations, but also jeopardizes public confidence and trust in video gaming.  We made 11 recommendations, which, if implemented, should significantly improve the Lotteryï¿½s effectiveness in administering and monitoring VLT operations to ensure that the Government receives all revenues and taxes to which it is entitled.  


In your February 2, 2007 response to our draft report (Appendix 4), you concurred with Recommendation Nos. 1, 2, 3, 6, 9, and 10 and indicated that actions had been taken to address Recommendation Nos. 4, 5, 7, 8, and 11.  Based on your response, we consider Recommendation Nos. 1 and 4 to be resolved and implemented; Recommendation Nos.ï¿½2, 3, 6, 9, and 10  to be resolved, but not implemented; and Recommendation Nos. 5, 7, 8, and 11 to be unresolved.  The status of the audit recommendations is shown in Appendixï¿½5.


The legislation, as amended, creating the Office of Inspector General (OIG) requires that we report to Congress semiannually on all audit reports issued, the monetary effect of audit findings, actions taken to implement our audit recommendations, and recommendations that have not been implemented.  This report will therefore be included in our next semiannual report to Congress.


Please provide a response to this report by July 13, 2007, and send the response to:


	Ms. Anne L. Richards
	Assistant Inspector General for Audits
	U.S. Department of the Interior
	1849 C Street, NW, MS 5341
	Washington, D.C.  20240


Also send a copy of the response to our Mr. Hannibal Ware, Field Office Supervisor, Office of Inspector General, Caribbean Field Office, Ron deLugo Federal Building, Room 207, Charlotte Amalie, Virgin Islands  00802.  The response should provide the information requested in Appendix 5.

We appreciate the cooperation shown by Government staff during our audit.  If you have any questions concerning this report, you may contact me at (916) 978-5653 or Mr. Ware at (340) 774-8300.
        

						Sincerely,
	
						/signed/
	
						Michael P. Colombo
						Regional Audit Manager

Enclosure

cc:	Executive Director, Virgin Islands Lottery 
	Chairperson, Virgin Islands Lottery Commission

	
CONTENTS

INTRODUCTION
Background						1
Objective 						3

RESULTS OF AUDIT
  Lottery Has No Effective Oversight of VLT Operations	4
  Unrealized Tax Revenues 				4
  Lack of Operational Control			 	5
  Flawed Contract and Master Lease Agreement		7
  Monitoring Deficiencies				7
  Lottery Payments to Special Government Funds		8
  Records Management Deficiencies			8		

RECOMMENDATIONS
  To the Governor of the Virgin Islands			10
  Governorï¿½s Response and OIG Reply			10

APPENDICIES
  1.  Monetary Impact					11
  2.  Audit Scope and Methodology			13
  3.  List of Video Lottery Retailers			15
  4.  Governorï¿½s Response				17
  5.  Status of Audit Recommendations			31

Acronyms

GLI	Gaming Laboratories International
OIG	Office of Inspector General
SGVI	Southland Gaming of the Virgin Islands
VIC	Virgin Islands Code
VLT	Video Lottery Terminal




INTRODUCTION

Background

The Virgin Islands Lottery (Lottery) was created by statute in 1937 and established as an independent instrumentality of the Government of the Virgin Islands in 1971.  Lottery operations are managed by an Executive Director, who is subject to supervision by a seven-member Lottery Commission.  The Virgin Islands Code (VIC) specifies the powers and duties of the Executive Director and the Lottery Commission.

In 1998, a contract was awarded to Southland Gaming of the Virgin Islands (SGVI)1 to operate video lottery terminals (VLT) in the Virgin Islands if and when video lottery gaming became legal.  VLT operations were originally established on the Virgin Islands as a means to provide additional revenues to the Government.  The Governor, however, on three occasions, vetoed legislation to revise the VIC to authorize VLTs.  The Legislature voted to override the Governorï¿½s latest veto in December 2002, and on that basis, SGVI installed and operated VLTs at three locations on St.ï¿½Thomas from January through April 2003.

Attempts by the Legislature to repeal the law authorizing VLTs prompted a lawsuit by SGVI and a countersuit by the Government.  After the repeal legislation failed, the Government and SGVI dropped their respective lawsuits.  In July 2003, the Lottery and SGVI negotiated a new contract allowing SGVI to install VLTs at retail locations on St.ï¿½Thomas and St.ï¿½John.  Full-scale VLT operations began in August 2003.  In December 2003, the Lottery and SGVI entered into a Master License Agreement, which expanded the July 2003 contract.  As of February 2006, 489ï¿½VLTs were located at 42 retailers on St.ï¿½Thomas and St.ï¿½John.

Based on information provided by SGVI, we estimated that during calendar years 2003, 2004, and 2005, VLTs received about $87ï¿½million in cash and paid out about $61ï¿½million, or 70ï¿½percent, in prizes.  The $26.1ï¿½million in net gaming proceeds was distributed as follows:

   -  $5.7 million (22 percent) among the retailers where
      VLTs were	located,
   -  $8.3 million (32 percent) to the Lottery, and
   -  $12.1 million (46 percent) to SGVI (see Figure 1).

																																																																							
Figure 1.  Summary of VLT Receipts

(TABLE, see PDF version - page 2)


The distribution of net gaming proceeds among SGVI, retailers and the Lottery is determined based on VLT contract stipulations and retailer rules and regulations.  Share percentages are as follows:

(TABLE, see PDF version - page 3)


Objective

We conducted our audit to determine whether the Lottery adequately controlled VLT operations on St. Thomas and St. John.  Our scope and methodology are detailed in Appendix 2.


RESULTS OF AUDIT

LOTTERY HAS NO EFFECTIVE OVERSIGHT OF VLT OPERATIONS
The Lottery has exercised virtually no oversight of VLT operations on St. Thomas and St. John.  We found serious deficiencies, such as substantial unrealized tax revenues, an overall lack of operational control, a flawed contract and master lease agreement, an absence of monitoring, neglect of payment to special Government funds, and insufficiencies in records management.  The Lottery allows SGVI to control every aspect of video gaming from equipment installation to revenue collection and remittance and has no records to show whether VLT-related revenues or appropriate taxes have been paid to the Government.  The lack of any working system of checks and balances over VLT operations significantly increases the risk of fraud, waste, and abuse of VLT revenues and undermines public confidence and trust in VLT operations.  We were unable to determine the exact amount of unrealized revenues because the Lottery failed to obtain and maintain the financial documents necessary to make such a determination, although we believe unrealized revenues may be in the millions.  

Potential Unrealized Tax Revenues
The primary goal of introducing VLTs in the Virgin Islands was to generate additional Government revenues.  However, the Lottery failed to ensure that these Government tax revenues were maximized.  Specifically, it did not monitor SGVI performance to ensure that appropriate taxes were withheld, gross receipts taxes were handled properly, and corporate income taxes were paid to the Government of the Virgin Islands.

Tax Withhholding
An SGVI official told us that SGVI withholds 25 percent from VLT prizes of more than $5,000 for remittance to the Bureau of Internal Revenue.  As the oversight agency, however, the Lottery has no mechanism in place to determine whether SGVI actually withheld or remitted the correct amounts.  Additionally, a Bureau of Internal Revenue official told us that the Bureau could not determine if SGVI deposited amounts withheld for individuals.  Without a mechanism to ensure that withholding was remitted by SGVI, the Lottery had no assurance that SGVI either deducted or remitted the 25ï¿½percent withheld from winnings over $5,000.  

Gross Receipts Taxes
Without legislative authority, the Lottery expanded the definition in the VIC of ï¿½commissionsï¿½ paid for the sale of lottery tickets to include VLT gaming proceeds.  These commissions were exempt from gross receipts taxes to help lottery ticket dealers, who were usually individual local residents.  By expanding the definition to include gaming proceeds, the Lottery, in effect, made all VLT revenues exempt from gross receipts taxes.  As a result, the Government did not realize $3.5ï¿½million in gross receipts tax revenues that would have been paid had theï¿½4percent tax rate been applied to the $87ï¿½million in gross revenues.  Retailers would also have owed 4 percent on their profits of nearly $6ï¿½million, resulting in additional tax revenues of $240,000.

Corporate Income Tax
The VIC requires individuals and corporations conducting business in the Virgin Islands to file income tax returns; however, according to the Bureau of Internal Revenue, it had no record of SGVI having filed corporate income tax returns in the Virgin Islands for fiscal years 2003 through 2005.2  Because SGVI is not required to submit audited annual financial statements to the Lottery, neither we nor the Lottery could determine the amount of corporate income tax that should have been paid. 

Lack of Operational Control
We identified several shortcomings in regard to operational control, including unmonitored cash collections, inadequate testing of VLT machines, and an overall lack of security.   

Cash Collections
The Lottery neither participated in nor monitored the removal of cash receipts and betting and payout data from VLT machines.  It also did not reconcile weekly VLT revenue statements provided by SGVI with payment checks for the Lotteryï¿½s share of net gaming proceeds.  The Lottery was therefore unaware of errors in remittance computations involving its share of gaming revenues which we brought to the attention of Lottery officials.  At the majority of retail locations, retailers removed cash receipts from VLTs at the end of each business day and deposited the funds into their individual business accounts.  

SGVI downloaded data from internal counters in the VLTs that recorded the amount of cash put into the machine by customers and the amount paid out on a weekly basis.  SGVI used this data to determine the amount retailers were entitled to keep and the amount retailers must pay SGVI. SGVI also used the data to prepare manual revenue statements and make weekly payments to the Lottery.  This practice is contrary to established gaming controls.
For example, in New Jersey, all gaming machines have double-locked compartment, with one key controlled by the casino and the second key controlled by the casino-control commission.  The double-locked internal control technique ensures that gaming receipts are accurately and completely accounted for and that receipts are not improperly removed from machines.  Because the Lottery did not monitor cash collections, it was totally dependent on SGVI data and could not verify the accuracy of that data.

VLT Testing
Despite contract stipulations, the Lottery failed to test VLTs before or immediately after operation began.  Without documented evidence that specific machines were tested and the results of those tests, the Lottery could not ensure that VLTï¿½s were operating properly.  Testing is a standard protocol within the gaming industry.

Lottery and SGVI representatives told us that the VLTs installed in the Virgin Islands were originally salvaged from an Indian casino in the United States and then reconfigured for use in the Virgin Islands.  An SGVI report indicates that Gaming Laboratories International (GLI) tested VLTs prior to their shipment to St.ï¿½Thomas, but failed to identify which machines were tested.  In July 2005, the Executive Director of the Lottery told us that he was waiting on approval of a contract with GLI to test the VLTs already operating in the Virgin Islands.  At the April 24, 2006 exit conference, Lottery officials presented documentation indicating the first phase of testing had begun in January 2006.

Security
VLTs operate on a computer-based system subject to the wide range of risks associated with computer technology.  The Lottery has failed to appropriately assess these risks and lacks a comprehensive security program to protect the systemï¿½s sensitive proprietary and financial data.

[Ex.2] 

[Ex. 2] 

[Ex. 2]


Flawed Contract and Master Lease Agreement
The contract and master license agreement lacked key provisions to protect the financial interest of the Government.  This condition, coupled with the failure of the Lottery to effectively monitor VLT operations, left the Lottery with little or no control over VLT operations.  

Audited Financial Statements
Five years before lottery operations were legal in the Virgin Islands, SGVI secured a contract with the Lottery as the sole operator of VLTs.  The subsequent contract and master license agreement did not require annual audited financial statements from SGVI.  Without annual audited financial statements, the Lottery cannot determine whether its share of net gaming proceeds is based on actual revenues collected by SGVI. 

Minimum Payout Rates
The contract and master license agreement also failed to establish a minimum payout rate for VLTs, which is contrary to standard gaming protocol.  For example, the Nevada Gaming Commission and State Gaming Control Board is governed by a minimum payout rate to ensure ï¿½public confidence and trust that gaming is conducted honestly and competitively, that the rights of the creditors of licensees are protected and that gaming is free from criminal and corruptive elements.ï¿½  While established payout rates can vary,3 establishing minimum rates is a vital control over gaming.  VLT revenue data from SGVI suggest an average payout rate of about 70ï¿½percent, but there is no guarantee that such a rate will continue absent a legal or contractual minimum payout requirement. 

Monitoring Deficiencies
The Lottery also did not monitor compliance with the contract requirement that at least 65ï¿½percent of goods and services (with the exception of gaming hardware, software, and machines) be purchased from Virgin Islands companies.  This requirement was established to assist in fostering the economic development of the Virgin Islands.  We obtained expenditure information directly from SGVI to determine that SGVI had met this requirement.  This does not absolve the Lottery from its responsibility to monitor compliance with this requirement.

Licensing Fees
The master license agreement requires that SGVI pay an annual license fee to operate VLTs in the Virgin Islands.  The Lottery, however, could not provide documentation showing that SGVI paid $6,000 in license fees for 2004 ($2,800) and 2006 ($3,200).

Lottery Payments to Special Government Funds
The Lottery failed to pay $807,983 in VLT revenues to two special Government funds:  25 percent to the Virgin Islands Educational Initiative Fund and 15 percent to the Pharmaceutical Assistance to the Aged Program, as required by the VIC.4  As of December 2005, the Lottery had paid almost $1.6ï¿½million into the Educational Initiative Fund, with $443,898 still owed, and $829,652 into the Assistance to the Aged Program, with $364,085 still owed.  The VIC requires that payments to both funds be made in four quarterly installments.  At the April 24, 2006 exit conference, Lottery officials stated that the Lottery was now current with transfers to the special funds.

Records Management Deficiencies
We identified several areas of deficiency in records management, including the Lotteryï¿½s failure to (1) maintain complete and up-to-date files for retailer applicants, (2)ï¿½ensure applicants submitted required documents, and (3)ï¿½assign qualified staff to manage retailer files.  

Management of Retailer Accounts
Rules and regulations established by SGVI and approved by the Lottery require retailer applicants to complete a one-page application form, submit a copy of their police record (even if it is a ï¿½no infraction on recordï¿½ report) and a passport-size photo, and provide other pertinent documentation.  Both SGVI and the Lottery are responsible for approving applications; however, the Lottery plays no role in determining the locations and quantities of VLTs to be installed at each retail site.  

Of the 42 active retailer files, the Lottery could provide only 35 files because files were not available for the remaining 7.  We found application files to be incomplete, disorganized, and missing at least one piece of required information.  For example:  

> 12 applicants did not submit required police records or passport photos.
> 32 applicants did not provide floor plans of their business establishments.
> 34 applicants did not submit copies of current business licenses.
> 5 applicants did not submit completely filled-out application forms.
> 22 applications did not show the date of approval by the Lottery.

Our review of the Lotteryï¿½s updated retailer files revealed that the Lottery did not have files for three retailers included in SGVIï¿½s most current list of retailers.  SGVI had files for 42ï¿½active retailer locations, while the Lottery had files for 59ï¿½retailers, without differentiation among files for active retailers, inactive retailers, and applications in process.  

The Lottery did not monitor the movement of VLT machines at or among retail locations.  The number of current approved retailers or installed machines had to be obtained directly from SGVI because no Lottery officials or employees interviewed knew this information. 

Although VLT operations began in August 2003, the Lottery did not make a concerted effort to compile and organize retailer application files until December 2005.  Even then, the Lottery did not assign a specific employee as custodian of the files.  The Lotteryï¿½s Director of Enforcement maintained original documents for 9 retailers in his office filing cabinet, and the Lotteryï¿½s Director of Technology maintained 35 retailer applications (some duplicates) in a manila folder in his office.  


RECOMMENDATIONS

We recommend that the Governor of the Virgin Islands direct the Bureau of Internal Revenue to:

1. Determine whether VLT gaming proceeds are taxable under the gross receipts tax laws.

2. Ensure that SGVI has remitted VLT prize winning withholdings in accordance with tax law.

3. Ensure that SGVI files corporate income tax returns in the Virgin Islands and pays any corporate taxes due.

We recommend that the Governor of the Virgin Islands direct the Lottery to:

4. Update its records on retailer applicants.

5. Establish and implement procedures to ensure the accuracy of SGVI payments.  

6. Establish and implement procedures for cash collection.

7. Ensure that on-going and independent testing is performed on all VLTs in the Virgin Islands.

8. Establish and implement security protocol.

9. Obtain audited annual financial statements for VLT operations in the Virgin Islands prepared in accordance with Generally Accepted Accounting Principles.

10. Revise the existing VLT contract and master license agreement to include a minimum payout rate and physical and computer controls over VLT operations.

11. Confirm that SGVI has paid required annual license fees for 2004 and 2006 and ensure annual fees are collected timely in the future.

In his February 2, 2007 response to our draft report (Appendix 4), the Governor of the Virgin Islands, through the management of the Lottery, concurred with 6 of the 11ï¿½recommendations and stated what action will be taken to implement the recommendations.  All six recommendations were related to the failure of the Lottery to ensure that the Government received all the VLT related revenues and taxes to which it was entitled.  The Governor did not concur with the remaining five recommendations, indicating that corrective action had already been taken.  Based on the response, we consider Recommendation Nos.ï¿½1 and 4 to be resolved and implemented, Recommendation Nos. 2, 3, 6, 9, and 10 to be resolved, but not implemented, and Recommendationï¿½Nos. 5, 7, 8, and 11 to be unresolved.  Appendixï¿½5 describes the status of the audit recommendations and the actions required for resolution.  

The response stated the Lottery has been verifying the accuracy of all payment receipts received from SGVI and immediately reconciling any outstanding differences.  At the time of the audit, however, gaming proceeds were not being reconciled to payment remittances to detect errors.

The response stated that prior to this audit, the Virgin Islands Lottery Commission entered into a contract with GLI to test and perform an audit on all machines.  However, in July 2005, the Executive Director told us that he was waiting on approval of a contract with GLI to test the VLTs already operating in the Virgin Islands, but that the contract was never provided.  At the April 24, 2006 exit conference, Lottery officials presented documentation indicating the first phase of testing had begun in January 2006.  At the time of our audit, however, on-going and independent testing was not being performed on all VLTs in the Virgin Islands.

The response stated that the Lottery has established and implemented a proper security protocol and provided a copy of Standard Operating Procedures that was not available during the audit.  While Standard Operating Procedures are in place, they do not address any of the security issues detailed in the report, such as a comprehensive security program to protect the systemï¿½s sensitive proprietary and financial data.

The response stated the Lottery has verified that all annual license fees for 2004 and 2006 were collected.  At the time of the audit, however, the Lottery could not provide evidence that these fees had been collected and has yet to provide documentation showing the collection of these fees. 


APPENDIX 1
MONETARY IMPACT

Finding Area                                            Unrealized Revenues*

Revenue Collection 
  Potential Gross Receipts TAxes:
     Total Revenues                                       $3,500,000
     Retailers                                               240,000

  Unpaid License Fees                                          6,000

                        Total                             #3,747,000

__________
* All amounts represent local funds.
                 


APPENDIX 2
AUDIT SCOPE AND METHODOLOGY 
                             
SCOPE AND METHODOLOGY
The scope of the audit included VLT operations and Lottery oversight from August 2003 through December 2005.  To accomplish our objective, we interviewed Lottery and SGVI officials.  We also reviewed contracts between the Lottery and SGVI; Lottery operating procedures; SGVI business plans and retailer policies; weekly statements of VLT revenues collected and distributed by SGVI; and other related documents at the Lottery, SGVI, retailer locations, and Virgin Islands Department of Finance and Bureau of Internal Revenue.  In addition, we researched standard protocols related to effective management of computer-based gaming within the United States and incorporated these protocols, as appropriate, into our findings and recommendations.  

Our audit was conducted in accordance with the Government Auditing Standards, issued by the Comptroller General of the United States.  Accordingly, we included such tests of records and other auditing procedures that were considered necessary under the circumstances.  As part of our audit, we evaluated the internal controls related to VLT revenue collection and distribution, contract compliance, selection and approval of retailer locations, file management, and VLT-related computer security.  We used the Federal Information Systems Controls Audit Manual issued by the U.S. Government Accountability Office as our guide for the computer security phase of the audit.  Internal control weaknesses identified in these areas are discussed in the Results of Audit section of this report.  The recommendations, if implemented, should improve internal controls in these areas.

PRIOR AUDIT COVERAGE
A May 2001 OIG audit report on Lottery operations (Noï¿½01-I-290) found deficiencies related to the use of Lottery funds, collection of Lottery ticket revenues, controls over unsold lottery tickets, distribution of net Lottery revenues, financial statement audits, records management, and supervision of computer operations.  Three of the reportï¿½s 16ï¿½recommendations were resolved by the time the final report was issued.  In September 2003, the Lottery provided documentation indicating that the remaining 13ï¿½recommendations had been implemented.

FISCAL YEAR 2004 FINANCIAL STATEMENT AUDIT REPORT
A November 2005 audit report Virgin Islands Lottery Financial Statements, September 30, 2004, by an independent Certified Public Accountant on Lottery financial statements for the fiscal year ended September 30, 2004, found deficiencies similar to those discussed in our May 2001 report and in this report.  The November 2005 report included a qualified opinion on the financial statements and presented 15 internal control findings on the Lotteryï¿½s financial operations.  The findings, which included reportable conditions and material weaknesses, related to:

1. A lack of effective controls over financial reporting.
2. Failure to establish an escrow account for past due receivables.
3. Concerns about the integrity of high payouts at certain Lottery sites.
4. Inadequate verification of accounts receivable.
5. Inadequate controls over delinquent Lottery sales agents. 
6. Inadequate training of financial staff and lack of segregation of duties.
7. Inadequate maintenance of supporting documentation.
8. Improper use of daily cash collections for other purposes. 
9. Inadequate controls over purchasing and disbursement transactions.
10. Improper maintenance of fixed assets.
11. Inadequate controls over automated gaming systems operated by its third party contractor.
12. Untimely transfer of proceeds to the Government of the Virgin Islands.
13. Inadequate and ineffective controls over ticket sales.
14. Failure to obtain tax information on prize winners.
15. Improperly determined prize payments.  

Our current audit of VLT operations disclosed deficiencies similar to findings 1, 7, 11, 12, and 14 of the Certified Public Accountantï¿½s report.  We addressed these deficiencies in our findings and recommendations.


APPENDIX 3 
LIST OF VIDEO LOTTERY RETAILERS

(TABLE, see PDF version - page 15-16)


APPENDIX 4 
GOVERNORï¿½S RESPONSE

(see PDF version - page 17-30)


APPENDIX 5 
STATUS OF AUDIT RECOMMENDATIONS 

Finding/Recommendation:  1
Status:  Resolved and Implemented.
Action Required:  None.

Finding/Recommendation:  2
Status:  Resolved, Not Implemented.
Action Required:  Provide documentation of review of VLT prize winning withholdings.

Finding/Recommendation: 3
Status:  Resolved, Not Implemented.
Action Required:  Provide documentation of corporate income tax returns filed by Southland Gaming in the Virgin Islands.

Finding/Recommendation: 4
Status:  Resolved and Implemented.
Action Required:  None.

Finding/Recommendation:  5
Status:  Unresolved.
Action Required:  Provide the policies and procedures established that ensure the accuracy of SGVI payments. 

Finding/Recommendation: 6
Status: Resolved, Not implemented.
Action Required:  Provide documentation of established procedures for cash collections.

Finding/Recommendation: 7
Status:  Unresolved.
Action Required:  Provide documentation to show that independent testing and audits have been performed on all VLT machines in the Virgin Islands and the results of such testing and audits.   

Finding/Recommendation: 8
Status:  Unresolved.
Action Required:  Provide documentation to show that the security issues detailed in the report, such as a comprehensive security program to protect the systemï¿½s sensitive proprietary and financial data, have been included in the Standard Operating Procedures.

Finding/Recommendation: 9
Status:  Resolved, Not Implemented.
Action Required:  Provide documentation to show enforcement of contract option requiring SGVI to prepare and publish audited annual statements for VLT operations in the Virgin Islands. 

Finding/Recommendation:  10
Status:  Resolved, Not Implemented.
Action Required:  Provide copy of final Rules and Regulations requiring minimum payout rates and physical and computer controls over VLT operations.

Finding/Recommendation: 11
Status:  Unresolved.
Action Required:  Provide documentation of payments for $6,000 in unpaid license fees for 2004 and 2006. 



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