GRA Update — Understanding fraud


One of the express purposes of Section 1 of Title 15 — Gaming Regulatory Act is ”to provide a statutory basis for the regulation of gaming on Band Lands to ensure that gaming is shielded from organized crime and other corrupting influences, to ensure that the Band is the primary beneficiary of the gaming operation, and to assure that gaming is conducted fairly and honestly by both the operator and the player.”

GRA-promulgated regulations, our operating procedures, and our mission is to provide protection over the tribe’s biggest revenue sources. Our casino operators and countless different industries face many of the same occupational fraud threats. Understanding fraud, its red flags, and its impact help us and casino operators prepare for and detect fraud. We hope you find the following statistics interesting and helpful as we do.

The Association of Certified Fraud Examiners (ACFE) 2020 Report to the Nations shared the following data on occupational fraud and abuse:

• Organizations lose 5 percent of revenue to fraud each year. That’s over 4.5 trillion lost to fraud globally each year;
• Typical fraud case lasts 14 months before detection at a loss of $8,300 per month;
• Forty-three percent of fraud schemes were detected by a tip, and 50 percent of tips come from employees;
• Lack of internal controls contributed to nearly 1/3 of all fraud cases;
• Men committed 72 percent of all occupational fraud and also caused larger losses than women;
• Presence of Anti-fraud controls is associated with lower fraud losses and quicker detection;
• Twelve percent of fraudsters did not employ any attempts to conceal fraud;
• Occupational fraudsters who had been with their organization at least six years caused twice the loss of less-tenured employees;
• Sixty-four percent of occupational fraudsters had a university degree or higher; and
• Older occupational fraudsters caused much larger median losses.

At least one behavioral red flag was present in 85 percent of cases, and multiple red flags were present in 49 percent of cases. The seven most common red flags were:

• Living beyond means;
• Financial difficulties;
• Unusually close association with a vendor or customer;
• Excessive control issues, unwilling to share duties;
• Unusual irritability, suspiciousness, or defensiveness;
• General ”wheeler-dealer” attitude involving shrewd or unscrupulous behavior; and
• Recent divorce or family problems.

For more information on occupational fraud and abuse, visit the ACFE 2020 Report to the Nations:

To report any Mille Lacs Band Gaming Enterprise fraud, please call 320-384-4519.

The Mille Lacs Band Gaming Regulatory Authority (GRA) is an independent regulatory agency of tribal government established to separate the government’s regulatory function from the management function of the Gaming Enterprises.

More information and contact numbers can be found at You can also LIKE us on Facebook at Mille Lacs Band GRA.

GRA Board meetings are open to the public. Due to COVID-19, meetings are currently being conducted remotely using Zoom.