TABLE OF CONTENTS MINIMUM INTERNAL CONTROL STANDARDS (MICS)-------------------------------2 SEC.

MICS-02 POKER GAMES------------------------------------------------------------3

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MINIMUM INTERNAL CONTROL STANDARDS (MICS)

Revised July 2008 The following Minimum Internal Control Standards shall apply to all Licensed Poker Operators (LPOs) and all Licensed Poker Establishments; however, this Appendix is not applicable to any activities not expressly permitted in the Permit to Operate or other Appendices. In addition, should the terms in this Appendix be inconsistent with the Permit to Operate or other Appendices, the terms in the Permit to Operate or other Appendices shall prevail.

SEC. MICS-01 DEFINITIONS

The definitions in this Section shall apply to all sections of this part unless otherwise noted. Accountability means all items of cash, chips and customer deposits constituting the total amount for which the bankroll custodian is responsible at a given time. Cage means a secure work area within a Licensed Poker Establishment for cashiers and a storage area for the Licensed Poker Establishments bankroll. Cage Accountability Form means an itemized list of the components that make up the cage accountability. Chiprunner means a poker employee who transports chips/cash to or from a poker table and the cage. Count Room means a room where the cash drop from poker tables are transported to and counted. Count Team means personnel that perform the count of the poker table drop. Customer Deposits means the amounts placed with a cage cashier by customers, for the customers use at a future time. Dedicated Camera means a video camera required to continuously record a specific activity. Drop means the total amount of chips removed from drop boxes. Drop Box means a locked container affixed to the gaming table, into which the drop is placed. The game type, table number, and shift are indicated on the box. Drop Box Contents Keys means the keys used to open drop boxes. Drop Box Release Key means the key used to release drop boxes from tables. Drop Box Storage Rack Key means the key used to access the storage rack where drop boxes are secured. Fill means a transaction whereby a supply of chips is transferred from a bankroll to a poker table. Lammer means a plastic monetary marker used in transactions between dealers and chiprunners, to indicate how much money has been taken out of the dealers tray, and is owed to the dealer by the chiprunner. Metered Cabinet means a cabinet with two locks, installed inside the cage/vault area to safekeep the drop box keys when not in use. MICS means Minimum Internal Control Standards. Monitor and Record means that the surveillance system shall have the capability to display the image captured by a camera required by the standards in the Permit to

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Operate on a monitor in the surveillance room, and continuously record that image on a video recorder. Payout means a transaction associated with a winning event. Pit Podium means a stand located in the middle of the tables, used by LPO supervisory personnel as a workspace and a record storage area. Poker Room Bank means the operating fund assigned to the poker room or main poker room bank. Primary and Secondary Jackpots means promotional jackpots offered at certain poker games that can be won in addition to the primary jackpot. Progressive Jackpots means funds contributed to a poker table by and for the benefit of players. Jackpots are awarded to players based on a pre-determined event. PTZ Camera means a video camera which, at a minimum, possesses pan, tilt and zoom capabilities or features comparable thereto. Rake Circle means the area of a table where rake is placed. Shift means an eight-hour period, unless otherwise approved by PAGCOR, not to exceed twenty-four (24) hours. Rake Count means the count of the contents in a drop box. Surveillance Room(s) means the secure location(s) used for the surveillance of gaming establishments and gaming activities, as identified in the surveillance plan. Surveillance System means the system of cameras, monitors, recorders, printers, switches, selectors, and other necessary or ancillary equipment used for surveillance of Licensed Poker Establishments and gaming activities. Table Tray means the container located on poker tables where chips are stored, that are used in the game. Vault means a secure area within a Licensed Poker Establishment where cash and chips are stored.

SEC. MICS-02

POKER GAMES

A. Computer Applications For any computer applications utilized, alternate documentation and/or procedures that provide at least the level of control described by the standards in this Section, as approved by PAGCOR, will be acceptable. B. Standards for Drop and Count The procedures for the collection of the poker game drop and the count thereof shall comply with SEC MICS-04 (as applicable). C. Standards for Supervision 1. Supervision shall be provided at all times the Licensed Poker Establishment is in operation, by personnel with authority equal to or greater than those being supervised. 2. Exchanges between table banks and the poker room bank (or cage, if a main poker room bank is not used) shall be authorized by a supervisor and verified by the dealer

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and chiprunner. All exchanges shall be evidenced by the use of a lammer, unless the exchange of chips takes place at the table. 3. Transfers between the main poker room bank and the cage shall be properly authorized and documented. D. Standards for Playing Cards 1. Playing cards shall be maintained in a secure location to prevent unauthorized access and to reduce the possibility of tampering. 2. Used cards shall be maintained in a secure location until marked, scored, or destroyed, in a manner approved by PAGCOR, to prevent unauthorized access and reduce the possibility of tampering. 3. PAGCOR, or the LPO as approved by PAGCOR, shall establish and the LPO shall comply, within a reasonable time period which shall not exceed three (3) days within which, to mark, cancel, or destroy cards from play. This standard shall not apply where playing cards are retained for an investigation. 4. A card control log, which documents when cards are received on site, distributed to and returned from tables, and removed from play, shall be maintained by the LPO. E. Plastic Cards If the LPO uses plastic cards (not plastic-coated cards), the cards may be used for up to three (3) months, if the plastic cards are routinely inspected and washed or cleaned in a manner and time frame approved by PAGCOR. F. Standards for Equipment and Paraphernalia a. b. c. d. 1. Poker Tables Must measure_______. Must be covered with _______material. Must have the following markings on the layout: PAGCOR Logo A single betting line Must have provisions for the following: i. House Rake Drop Box (right side of the dealer) ii. Jackpot Rake Drop Box (left side of the dealer) iii. Tip Box (left side of the dealer) iv. Dealers chip tray (for change only) 2. Tip Boxes One per dealer With personal identification of the dealer Kept locked except during counting 3. ChipTrays 4. Chips inventory per table per limit 5. House Buttons 6. Clock for each poker table 7. Chairs 8. Shuffling machine G. Standards for Reconciliation of Poker Room Bank

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1. The amount of the main poker room bank shall be counted, recorded, and reconciled on at least a per shift basis. 2. At least once per shift, the table banks that were opened during that shift shall be counted, recorded, and reconciled by a dealer or other person, and a supervisor, and shall be attested to by their signatures on the check-out form. H. Standards for Progressive Bad Beat Jackpots 1. All funds contributed by players into the jackpots shall be returned when won in accordance with the posted rules, subject to twenty percent (30%) administrative fee. 2. Rules governing progressive jackpots shall be conspicuously posted and designate: a) The amount of funds to be contributed from each pot. b) What type of hand it takes to win the jackpot (e.g., What constitutes a Bad Beat?). c) How the promotional funds will be paid out. d) How/when the progressive jackpot rake is added to the posted jackpots; and e) Amount/percentage of progressive jackpot rake allocated to primary and secondary jackpots, if applicable. 3. Progressive jackpot rake shall not be placed in or near the house rake circle, in the house rake drop box, or co-mingled with gaming revenue from poker games, but in the progressive jackpot rake drop box. 4. The amount of the progressive jackpot shall be conspicuously displayed in the poker room. 5. At least once a day, the posted progressive jackpot amounts shall be updated to reflect the current amounts. 6. At least once a day, increments to the posted progressive jackpot amounts shall be reconciled to the cash previously counted or received by the cage, by personnel independent of the poker room. 7. All decrements to the progressive jackpot amounts must be properly documented, including a reason for the decrement. I. Progressive Bad Beat Jackpot Rake Maintenance 1. Progressive jackpot rake shall be placed in a locked drop box. 2. Persons authorized to transport the locked drop box shall be precluded from having access to the contents keys. 3. The contents key shall be maintained by PAGCOR Poker Monitoring Assistants and/or PAGCOR Treasury Personnel. 4. At least once a day, the locked jackpot rake drop box shall be removed by two persons employed by the LPO, one of whom is independent of the poker games department, along with PAGCOR representatives, and transported directly to the count room or other secure room to be counted, recorded, and verified, prior to depositing said funds to PAGCOR Treasury.

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5. The posted progressive jackpot amounts shall then be updated to reflect the current progressive jackpot amounts.

SEC. MICS-03 THE CAGE

A. Computer Applications For any computer applications utilized, alternate documentation and/or procedures that provide at least the level of control described by the standards in this Section, as approved by PAGCOR, will be acceptable. B. Customer Deposited Funds If the LPO permits a customer to deposit funds at their cage, the following standards shall apply: 1. A file for customers shall be prepared, prior to acceptance of a deposit. 2. The receipt or withdrawal of a customer deposit shall be evidenced by at least a twopart document, with one copy going to the customer and one copy remaining in the cage file. 3. The two-part receipt shall contain the following information: a.The same receipt number on both copies. b.Customers name and signature. c.Date of receipt and withdrawal. d.Amount of deposit/withdrawal; and e.Nature of deposit (cash or chips); however, f. Provided all of the information in paragraph (B) (03) (a through e) is available, the only required information for all copies of the receipt is the receipt number. 4. PAGCOR or the LPO as approved by PAGCOR, shall establish and the LPO shall comply with procedures that: a. Maintain a detailed record by customer name and date of all funds on deposit. b.Maintain a current balance of all customer cash deposits that are in the cage/vault inventory or accountability; and c. Reconcile this current balance with the deposits and withdrawals at least daily. 5. The LPO, as approved by PAGCOR, shall describe the sequence of the required signatures attesting to the accuracy of the information contained on the customer deposit or withdrawal form, ensuring that the form is signed by the cashier. 6. All customer deposits and withdrawal transactions at the cage shall be recorded on a cage accountability form, on a per shift basis. 7. PAGCOR, or the LPO as approved by PAGCOR, shall establish and the LPO shall comply with procedures that verify the customers identity, including photo identification. C. Cage and Vault Accountability Standards

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1. All transactions that flow through the cage shall be summarized on a cage accountability form, on a per shift basis, and shall be supported by documentation. Errors on cage and vault documentation shall be corrected by drawing a single line through the error on the document, writing the correct figure above the original figure, and initialing the correction. All entries shall be recorded in ink or other permanent form of recording in the LPOs records. At the end of each shift, all documentation for the shift shall be delivered to the LPOs Accounting Department. 2. The cage and vault (including table trays) inventories, shall be counted by the incoming and outgoing cashiers. These employees shall make individual counts for comparison of accuracy and maintenance of individual accountability. Such counts shall be recorded at the end of each shift during which activity took place. All discrepancies shall be noted and investigated. 3. The cash-on-hand in a poker room shall include, but shall not be limited to, the following: a. Currency and coins. b. House chips, including reserve chips and tournament chips. c. Customer deposits. d. Chips on the poker tables. e. Fills and credits (these documents shall be treated as assets and liabilities respectively, of the cage during a business day. When income is recorded at the end of the business day, they are removed from the accountability). D. Accounting/Auditing Standards 1. The cage accountability shall be reconciled to the general ledger, at least monthly. 2. All cage and credit accounting procedures and any follow-up performed shall be documented, maintained for inspection, and provided to PAGCOR upon request. E. Added Cage and Vault Access The cage and vault shall be required to be secure at all times (e.g., doors locked, surveillance cameras operational, and alarm systems operational). A cage access log shall be updated manually or electronically, each time anyone enters the cage. A vault access log shall be updated manually or electronically, each time anyone enters the vault.

SEC. MICS-04 DROP AND COUNT FOR A LICENSED POKER ROOM

A. Computer Applications For any computer applications utilized, alternate documentation and/or procedures that provide at least the level of control described by the standards in this Section, as approved by PAGCOR, will be acceptable.

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B. Drop Box Standards Shall indicate the game type, table number, and shift. Color Coded to be used alternately. Affixed to the table with a lock. With two locks to secure the contents. Separate drop boxes shall be used for the house rake and jackpot rake. C. Drop Box Handling Procedures 1. At the beginning of each operating day, all authorized tables shall be issued the required empty drop boxes. 2. At the end of each operating day, all locked drop boxes shall be removed from the tables by a person independent of the pit shift being dropped. 3. Immediately after removal from the tables, the drop boxes shall be brought to the count room or other equivalently secure area until the actual count takes place. 4. The drop boxes shall be brought to the count room by a minimum of two LPO personnel, at least one of whom is independent of the shift being dropped, along with the PAGCOR representative. 5. Access to the drop boxes shall be restricted to authorized members of the count team. D. Metered Cabinet For Drop Box Keys 1. A metered cabinet with two locks shall be installed inside the cage/vault area to safekeep the following when not in use: a) b) Jackpot Rake and House Rake Drop Box Release Key Jackpot Rake and House Rake Drop Box Contents Keys

2. The metered cabinet shall be conspicuously located inside the cage/vault with full CCTV coverage. 3. The keys to the locks of the metered cabinet shall be held separately by the LPO and authorized PAGCOR representative. 4. Only authorized personnel shall have access to the metered cabinet. 5. Withdrawal and deposit of the drop box keys shall be recorded in a logbook which shall contain the following information and their corresponding meter readings: a. Type of key b. c. d. Time and Date Purpose Signatures of personnel involved

E. Drop Box Release Key Control Standards 1) The drop box release key shall be safekept in the metered cabinet when not in

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use. 2) Only authorized LPO personnel and PAGCOR representative shall withdraw/deposit the drop box release key from/to the metered cabinet. 3) Only persons authorized to remove drop boxes from the tables shall be allowed access to the drop box release key; however, the count team members may have access to the release key during the rake count in order to reset the drop boxes. 4) Persons authorized to remove the drop boxes shall be prohibited from having simultaneous access to the drop box release key and drop box contents keys 5) After the rake count or any authorized activity which requires its use, the drop box release key shall immediately be returned to the metered cabinet. F. Drop Box Contents Keys Control Standards 1) The drop box contents keys shall be safekept in the metered cabinet when not in use. 2) Only authorized LPO personnel and PAGCOR representative shall withdraw/return the drop box contents keys from/to the metered cabinet. 3) The drop box contents keys shall be returned to the metered cabinet immediately after the rake count. G. Duplicate Keys Control Standards All duplicate keys shall be safekept by the PAGCOR Poker Department. H. Rake Count Standards 1. The rake count shall be performed by the rake count team in the count room or other equivalently secure area. 2. Access to the count room shall be restricted to members of the count team. 3. The drop boxes shall be individually emptied and counted in a manner that their contents are clearly visible to the CCTV cameras and are not co-mingled with the contents of other drop boxes. 4. The count of each drop box shall be recorded in ink. 5. A second count shall be performed by an employee of the count team who did not perform the initial count. 6. Corrections to information originally recorded by the count team on rake count documentation shall be made by drawing a single line through the error, writing the correct figure above the original figure, and then obtaining the initials of at least two count team members and the PAGCOR representative who verified the correction. 7. Drop boxes, when empty, shall be shown to another member of the count team, the PAGCOR representative and to surveillance. 8. The count sheet [form _____] shall be reconciled to the total drop by a count team member and the PAGCOR representative. 9. All members of the count team shall sign a summary report to attest to their participation in the count. I. Rake Count Room Personnel 1. The rake count team shall be composed of a dealer and security

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personnel of the LPO. 2. During the count, nobody shall be allowed to enter/leave the count room. 3. Count team members shall be rotated such that the count team is not composed of the same two persons more than three (3) days per week. 4. The count team shall be independent of transactions being counted. The count team shall be independent of the cage/vault departments. A dealer or a cage cashier may be used if this person is not allowed to perform the recording function. An accounting representative may be used if there is an independent audit of all rake count documentations. 5. For LPOs not operating on a twenty-four (24) hour basis, the count team may be composed of dealers and security personnel of the same pit shift being dropped.

SEC. MICS-05 SURVEILLANCE FOR A LICENSED POKER ROOM

A. Maintenance and Operation The surveillance system shall be maintained and operated by the LPOs Surveillance Department from a staffed surveillance room and shall provide surveillance as required by the Permit to Operate and its Appendices. 1. During operating hours, the surveillance room must be staffed by at least one Surveillance Department employee trained in the use of the surveillance system. If a Licensed Poker Establishment is closed and in a lockeddown mode (i.e., the establishment is locked and no one is present in the establishment), the surveillance room is not required to be staffed, but the surveillance system must be set to record overviews of the poker room. At all other times, the surveillance room must be staffed by at least one Surveillance Department employee trained in the use of the surveillance system. 2. Notwithstanding the provisions of SEC. MICS-05 (A)(1), the surveillance room may be unstaffed for brief periods during poker room operating hours for reasons such as allowing surveillance room personnel to take meal breaks, to take other scheduled breaks, to use restrooms, to maintain the surveillance system, to review video, and/or to meet with others regarding surveillance-related matters. These periods may not be scheduled in a manner that creates a regular pattern allowing persons outside the surveillance room to ascertain when the surveillance room will be unstaffed. 3. Notwithstanding the provisions of SEC. MICS-05 (A) (1 and 2), the surveillance room may be unattended in the event of an emergency requiring evacuation or closure of the surveillance room, or if a scheduled surveillance employee is not available for his shift. If an emergency or employee unavailability causes the surveillance room to be left unattended, the surveillance system shall be set to record overviews of the poker room. The LPOs Surveillance Department shall notify PAGCOR immediately, and the surveillance room shall be staffed as soon as practicable. B. Entrance to the Surveillance Room

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The entrance to the surveillance room shall be located so that it is not readily accessible to either Licensed Poker Establishment employees who work primarily on the casino floor or the general public. The entrance to the surveillance room must be secured at all times, except during ingress and egress by authorized personnel. C. Access to the Surveillance Room Access to the surveillance room shall be limited to Surveillance Department employees, other designated employees, and other persons authorized in accordance with the Surveillance Department policy, and the surveillance plan. Such policy shall be approved by PAGCOR. The Surveillance Department shall maintain a log of all persons entering the surveillance room. The log may be electronic, written, or a combination thereof. The Surveillance Department shall provide a copy of the log to PAGCOR at least monthly, unless PAGCOR requires the log to be provided more or less frequently. The Surveillance Departments policies and procedures shall prohibit the use of cellular telephones or radio equipment in the surveillance room, except as expressly authorized by those policies and procedures. D. Override Capability

Surveillance room equipment shall have total override capability over all surveillance equipment located outside the surveillance room. Only those surveillance equipment without recording capability shall be allowed outside the CCTV room. E. Power Loss

In the event of a power loss to the surveillance system, an auxiliary or backup power source shall be available and capable of providing immediate restoration of power to all elements of the surveillance system necessary to record the cameras required by the standards in this Section. Auxiliary or backup power sources such as a UPS system, a backup generator, or an alternate utility supplier satisfy this requirement. F. Display of Date and Time

The surveillance system shall have the capability to display the date and time of recorded events on digital video recordings. Recordings of all cameras required by the standards in this Section shall include the date and time (in 24 hour format), which shall not significantly obstruct the recorded view. G. Training of Surveillance Employees

The LPOs Surveillance Department employees shall be trained in the technical aspect and use of the surveillance equipments, knowledge of the games, and house rules. Their expertise shall be validated and certified in accordance with PAGCOR standards. H. Design of Surveillance System The surveillance system shall be designed in a manner to prevent it from being readily obstructed, tampered with, or disabled by customers or employees. The surveillance system and each camera required by the standards in this Section shall be installed in a

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manner that will prevent them from being readily obstructed, tampered with, or disabled by customers or employees. If the standards in this Section require the use of a PTZ camera, the PTZ camera must be placed behind a smoked dome, one-way mirror, or similar material that conceals the camera from view, unless the design of the camera inherently conceals it from view. 1. LPO must submit two (2) copies of the floor / table layout to the Surveillance Unit, Security Department, PAGCOR, for the preparation of camera layout and camera distribution, CCTV equipment and its adjuncts that are deemed necessary in effectively monitoring the operations of the LPOs. 2. The policies and procedures of the LPOs Surveillance Department must prohibit employees from intentionally obstructing, tampering with, or disabling surveillance system equipment, excepting only Surveillance Department employees who have been authorized to disable surveillance system equipment for maintenance, relocation, removal, or the like. 3. Each poker room must have the required room temperature and sufficient lighting and ventilation to permit clear video reproduction in the count room, in the cage/vault, in the surveillance room, and in all areas where poker games are being operated and in the other locations set forth in SEC. MICS-05 (L and M). I. Image Display

The surveillance system shall be capable of displaying the image captured by any camera required by the standards in this Section on a monitor and recording that image. 1. Each surveillance room shall be equipped with video monitor that is at least 12 inches in size, which is capable of displaying the image captured by any camera required by the standards in this Section, in accordance with the standards in this Section for that camera. 2. The surveillance system shall have video recorders that continuously record the images from all cameras required by the standards in this Section. For each camera required by the standards in this Section, the video recorders must be capable of recording and playing back the image captured by that camera, in accordance with the standards in this Section for that camera. J. Repair of Surveillance System

The Surveillance Department shall make reasonable efforts to repair each malfunction of surveillance system equipment required by the standards in this Section upon discovery of the malfunction. The Surveillance Department shall immediately notify PAGCOR of each required camera that has malfunctioned. If a malfunction in the surveillance system affects the ability to monitor or record the images from a camera required by the standards in this Section, the LPOs Surveillance Department shall immediately provide alternative camera coverage, other surveillance measures, or other security measures, such as additional supervisory or security personnel, to protect the subject activity. If other security or surveillance measures are taken, the LPOs Surveillance Department shall promptly notify PAGCOR.

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K.

Poker Games

The surveillance system shall monitor and record an overview of activities in each poker game area, sufficient to allow the employees performing the different functions to be identified. 1. At a minimum, the surveillance system shall provide one dedicated camera for each poker table and one PTZ camera for every four poker tables. (This standard requires, for example, two PTZ cameras for a poker room with five to eight poker tables, three PTZ cameras for nine to twelve poker tables, etc.) If a poker room has fewer than four poker tables, the surveillance system shall provide, at a minimum, one dedicated camera for each table and at least one PTZ camera for the tables. a.The required dedicated camera shall provide an overview of the poker table under surveillance, sufficient to allow the table surface, the table tray, the placement of wagers, and any shuffling device located at the table to be clearly viewed. b.The dedicated cameras and the PTZ camera(s), in combination, must be capable of monitoring and recording the customers, dealers, card suits, card values, and game outcome, sufficient to allow them to be clearly identified. c.If any poker games are serviced by a shuffling device that is not located at the table, then the remote shuffling device(s) shall be monitored and recorded by at least one dedicated camera providing a general overview of the shuffler, sufficient to allow employees accessing the shuffler to be identified and their activities to be monitored, and also sufficient to allow the movement of cards from the table to the shuffler and back to be monitored. This standard does not require one dedicated camera per remote shuffling device if one dedicated camera is able to provide the required coverage for more than one remote shuffling device. 2. The secure location in which unused and/or reserve gaming chip inventories for poker games are maintained shall be monitored and recorded by at least one dedicated camera providing a general overview of the area, sufficient to allow employees accessing the inventories to be identified and their activities to be monitored. The Surveillance Department shall be notified before persons enter the secure location. 3. The secure location in which unissued playing cards for poker games are maintained shall be monitored and recorded by at least one dedicated camera providing a general overview of the area sufficient to allow employees accessing the inventories to be identified and their activities to be monitored. The Surveillance Department shall be notified before persons enter the secure location. L. Cage and Vault 1. The surveillance system shall monitor and record, with at least one dedicated camera, a general overview of the activities occurring in each cage and vault area. The overview shall be sufficient to allow employees within the cage

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and vault areas to be identified and their activities to be monitored. 2. The surveillance system shall monitor and record, with at least one dedicated camera, an overview of activities at the cage counters sufficient to allow persons at the cage counters to be identified and their activities to be monitored. 3. Each cage cashier station shall be equipped with one (1) dedicated overhead camera covering the customer transaction area and all activity occurring in the customer transaction area. M. Currency and Chips 1. The surveillance system shall monitor and record all areas where currency and chips used for poker, and owned by the LPO, are stored or counted, sufficient to allow persons in those areas to be identified and their activities monitored. This provision does not apply to: a.Areas that are the subject of specific surveillance requirements in this Section, including, but not limited to those areas addressed in SEC. MICS-05 (M) (2) and, in particular, SEC. MICS- 05 (M) (2) (c) (v). b.Imprest banks of cash maintained on the person of employees. 2. Drop and Count Process: a.The surveillance system shall monitor and record all areas where chips may be stored or counted during the drop and count process, including the count room, all doors to the count room, and all areas where uncounted chips may be stored during the drop and count process, by dedicated cameras sufficient to allow persons in those areas to be identified and their activities to be monitored. b.The surveillance system shall provide for: i. Monitoring and recording of the drop box storage rack or area by a dedicated camera sufficient to allow persons in those areas to be identified and their activities to be monitored. ii. Monitoring and recording of all areas where the contents of drop boxes may be stored during the drop and count process, including the count room and all doors to the count room, by dedicated cameras sufficient to allow persons in those areas to be identified and their activities to be monitored. iii. Monitoring and recording of all areas where currency is sorted, stacked, counted, verified, or stored during the count process by dedicated cameras, sufficient to allow persons in those areas to be identified and their activities to be monitored. The counting surface area must be continuously monitored and recorded by at least one dedicated camera, sufficient to allow persons in the area to be identified and their activities to be monitored during the count. iv. Monitoring and recording an overview of activities at the currency counter and/or currency sorter, if the LPO uses a currency counter or currency sorter in the count room, by at least one dedicated camera, sufficient to allow persons in those areas to be identified and their activities to be monitored.

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v. The capability of monitoring and recording an overview of the following, sufficient to allow persons involved to be identified and their activities to be monitored: fills or exchanges, as they are transferred from the cage to a poker game. the drop, as it is transferred from poker games to the count room. N. Video Recording and/or Digital Record Retention 1. All digital video recordings of the images provided by the cameras required by the standards in this Section shall be retained for a minimum of ten (10) days. If PAGCOR requests that particular recordings be retained for a longer period of time, the LPO Surveillance Department shall retain those recordings for the time requested. 2. Recordings involving suspected or confirmed gaming crimes and/or unlawful activity must be retained for a minimum of thirty (30) days. If PAGCOR requests that particular recordings be retained for a longer period of time, the LPO Surveillance Department shall retain those recordings for the time requested. Duly authenticated copies of digital video recordings shall be provided to PAGCOR upon request. LPO Surveillance Department shall be capable of promptly producing a clear still copy or photograph of a clear image depicted on a digital video recording, using a video printer, still camera, or other comparable means. 3. Each Licensed Poker Establishment shall have a video monitor and a video player separate from the surveillance system at which PAGCOR, or other authorized persons may review digital video recordings. O. Video Library Log

The LPO Surveillance Department shall maintain data demonstrating compliance with the storage, identification, and retention standards required in this Section. The data shall include the camera name or number and the date and time each recording was made. The date maybe maintained in logs kept by the LPO Surveillance Department, by the surveillance system, or a combination of both. P. Malfunction and Repair Log 1. The LPO Surveillance Department shall maintain a log or alternative procedure approved by PAGCOR, documenting each malfunction and repair of the surveillance system, as defined in this Section. 2. The log shall state the time, date, and nature of each malfunction, the efforts expended to repair the malfunction, and the date of each effort, the reasons for any delays in repairing the malfunction, the date the malfunction is repaired, and, if applicable, any alternative security or surveillance measures that were taken. Q. Surveillance Log

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1. LPO Surveillance Department employees shall maintain a log of all surveillance activities which shall be stored securely, and which shall include, at a minimum: a.The date and time surveillance was commenced and terminated. b.The activity observed or performed (including any unusual occurrences and violations or suspected violations of the Permit to Operate or its appendices, including, but not limited to, the detection of illegal activities or suspected illegal activities, the detection of the presence in a poker room of barred persons or persons who are on the self-excluded list established under the Permit to Operate, the detection of gambling by persons who are less than twenty-one years of age, the detention of persons, or injuries to a patron or employee); and c.The name and employee identification number of each person who initiates, performs, or supervises the surveillance. 2. LPO Surveillance Department employees also shall record a summary of the results of the surveillance of any suspicious activity. This summary may be maintained in a separate log. R. Floor Plan

A floor plan of the poker room shall be available in the surveillance room. The floor plan shall show the location of and identify: 1. all poker tables by table number. 2. the location and layout of the cage and vault areas. 3. the location and layout of areas required to be surveilled by SEC. MICS-05 (M); and 4. the location of automatic teller machines. The floor plan shall also show the location of all surveillance cameras. The floor plan shall be updated promptly with any changes to the location or layout of the foregoing items or areas. S. Entrances, Exits, and other Areas

The LPOs Surveillance Department as approved by PAGCOR, shall establish and the Surveillance Department shall comply with standards for the surveillance of entrances to and exits from each Licensed Poker Establishment, including parking lots adjacent to the poker room primarily used by patrons or employees of the poker room. Those standards, at a minimum, shall require: 1. The LPO Surveillance Department to monitor and record each public entrance to, and public exit from, the poker room with at least one (1) dedicated camera, sufficient to allow persons using those entrances and exits to be distinguished. (A combination entrance/exit will require only one dedicated camera.). 2. The Surveillance Department to be capable of monitoring and recording all other entrances to, and all other exits from, each poker room sufficient

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to allow persons using those entrances and exits to be distinguished. 3. The Surveillance Department to be capable of monitoring and recording overviews of the grounds adjacent to each poker room, including parking lots adjacent to the poker room primarily used by patrons or employees of the poker room; and 4. The Surveillance Department to continuously record the images from all cameras.

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