Tag Archives: compliance

Compliance Innovation

Compliance innovation is the ability to identify and change compliance processes that are not working. Compliance managers need to communicate a sense that compliance processes are in place to look out for you and not over you. When you create this kind of culture, staff morale increases and non-compliance reduces radically. In order to facilitate compliance innovation, two things need to happen:

  • Remove unnecessary processes

If your ship is becoming slower, heavier and harder to handle, it’s a good sign that processes are being added but not removed. You’re in danger of sinking! Get each department to list their compliance processes and go on a culling spree.

  • Innovate processes that need to remain

An example of process innovation is the current sentencing and prison reform taking place in some American states. Driving these reforms is cost. Over the past two decades, spending on prisons has grown faster than any segment of states’ budgets except Medicaid. However, as states like Texas have changed failing processes, crimes of many kinds have declined and the incarceration rate fell by 4.5 %, while the nationally the rate rose slightly.

Just as Richard Nixon could open relations with China without being soft on communism, so compliance managers can push for compliance reform without being considered soft on compliance. Don’t forget, the word innovation means – “to renew or change” and not that latest gadget. Leave a legacy of compliance innovation and you will become in hot demand!

Who’s winning the casino procedures race?


The famous Jonny Walker whiskey brand has a well known slogan – “keep walking”. When the Hard Rock Hotel & Casino in Vegas was fined in February this year, Gaming Commissioner, Tony Alamo said the property failed its duty because upper management didn’t walk the property. The latest high profile fining has been Harrah’s Atlantic City who was fined $65,000 due to a security lapse. Is it also a walking problem?

Having worked with upper management and operational staff, my experience is that upper management need better management tools to hold staff members accountable. According to Noah Turner in iGaming Business Magazine (Dec 2008), The Bigger They Are, the Harder they Fall, “Compliance should never be overlooked. Failing to keep up can mean failing to make money. Administrative tools help an organization protect itself from the damaging effects of negligence and fraud both by external sources and an organization’s own staff, by ensuring that policies and procedures are strictly followed.” Does the surveillance executive have a tool that helps him/her manage casino procedures that are being violated (see an example of such a tool)? Procedure violations have a life cycle and must be managed by a smart work flow system that keeps track of the incident until everyone involved has been held accountable.  This list of casino procedures that need to be managed smartly is vast and requires smart casino management systems.

Gaming commissioners want upper management to walk their properties but in reality that’s not always possible. What they’re really saying is “create a culture of compliance”. As I mentioned in “creating a culture of compliance”, it starts by making small changes. That’s what the word innovation means – “to renew or change”. Make 2011 a year of innovation and increase your running speed. You’ll have more time for walking and you’ll enjoy it. If things are running well, “keep running”!

Creating a culture of casino compliance

Social scientist Randy Garner wondered whether sticky notes made by 3M Corp, might have the power to enhance compliance with a written request made to another person. In an intriguing study, he sent out surveys to people with a request to complete them. The survey was accompanied by either

  • a handwritten sticky note requesting completion of the survey, which was attached to a cover letter;
  • a similar handwritten message on the cover letter; or
  • the cover letter and survey alone

More than 75 % of the people who received the survey with the sticky note request filled it out and returned it, whereas only 48 % of the second group and 36 % of the third group did so.

Garner suggests that people recognize the extra effort and personal touch that a handwritten sticky note requires, and they feel the need to reciprocate this personal touch by agreeing to the request.

“Casino compliance should never be overlooked. Failing to keep up can mean failing to make money. Administrative tools help an organization protect itself from the damaging effects of negligence and fraud both by external sources and an organization’s own staff, by ensuring that policies and procedures are strictly followed.” iGaming Business Magazine (Dec 2008).

Below is an example of a compliance message that was automatically generated by cheeteye because of a casino procedure break.

The image below is how that message will look in our new release that will be available soon i.e. it will give the manager an option to add a personal message. The system currently tracks all compliance messages that get sent and notifies the surveillance department of outstanding replies. We’re hoping that with the personal “sticky note”, compliance awareness is going to be enhanced and surveillance departments will have another tool for creating a culture of casino compliance.

According to Darrin Hoke in his chapter on innovation in “There’s no crying in surveillance”, “There are some analytics and dataveillance concepts floating around out there in our world, but they aren’t where they need to be yet.” According to wikipedia, innovation means to “renew or change”. Rather than wait for something to be where it is, make small changes to processes that are not working and you won’t fall behind when it comes to innovation. That’s what we’re doing with our clients and their surveillance department’s are smiling.