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Harvard Case - Controls at the Sands Hotel and Casino

"Controls at the Sands Hotel and Casino" Harvard business case study is written by Kenneth A. Merchant, Jeffrey M. Traynor. It deals with the challenges in the field of Accounting. The case study is 25 page(s) long and it was first published on : Nov 22, 1983

At Fern Fort University, we recommend a comprehensive overhaul of the Sands Hotel and Casino's internal control system, focusing on strengthening financial controls, improving risk management, and enhancing corporate governance. This will involve a multi-pronged approach encompassing changes in accounting procedures, employee training, technology implementation, and organizational structure.

2. Background

The Sands Hotel and Casino, a leading entertainment and hospitality company, faces challenges related to its internal control system. The case study highlights concerns regarding potential fraud, inadequate segregation of duties, and a lack of robust financial reporting processes. These issues have led to a decline in investor confidence and raised concerns about the company's long-term sustainability. The main protagonists of the case study are the Sands' management team, the board of directors, and the company's internal auditors.

3. Analysis of the Case Study

The Sands' internal control weaknesses can be analyzed through the lens of the COSO framework, which outlines five key components of an effective internal control system:

  • Control Environment: The Sands' control environment lacks a strong ethical foundation, with a culture of complacency towards potential fraud and a lack of clear accountability.
  • Risk Assessment: The company has not adequately assessed the risks associated with its operations, particularly in areas like financial reporting, gaming operations, and employee misconduct.
  • Control Activities: Existing control activities are insufficient, with inadequate segregation of duties, weak authorization procedures, and limited monitoring of transactions.
  • Information and Communication: The information flow within the organization is fragmented, with limited communication between departments and a lack of transparency in financial reporting.
  • Monitoring Activities: Internal audit functions are not adequately resourced or empowered to effectively monitor the company's internal controls.

4. Recommendations

Financial Controls:

  • Implement Activity-Based Costing (ABC): Adopt ABC to accurately allocate costs across different departments and operations, providing a more granular view of profitability and identifying areas for cost optimization.
  • Strengthen Accounting Procedures and Policies: Develop and implement comprehensive accounting procedures and policies that comply with Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS). This includes establishing clear guidelines for revenue recognition, inventory valuation, and depreciation methods.
  • Enhance Financial Reporting: Improve the quality and transparency of financial reporting by implementing robust internal controls over financial reporting processes, including reconciliation of accounts, independent review of financial statements, and enhanced disclosure of key financial metrics.
  • Implement Strong Budgeting and Variance Analysis: Develop a comprehensive budgeting process that aligns with strategic objectives and includes detailed variance analysis to identify deviations from planned performance and implement corrective actions.

Risk Management:

  • Conduct a Comprehensive Risk Assessment: Identify and assess all major risks associated with the Sands' operations, including financial, operational, compliance, and reputational risks.
  • Develop a Risk Management Framework: Establish a comprehensive risk management framework that includes risk identification, assessment, mitigation, and monitoring.
  • Implement Internal Controls: Develop and implement specific internal controls to mitigate identified risks, including segregation of duties, authorization procedures, and independent verification of transactions.
  • Implement a Robust Fraud Detection System: Develop and implement a robust fraud detection system that includes employee training, whistleblower programs, and regular internal audits.

Corporate Governance:

  • Strengthen Board Oversight: Enhance the board of directors' oversight of the company's internal controls by providing them with regular reports on risk management and control activities.
  • Establish an Audit Committee: Establish a dedicated audit committee composed of independent directors with expertise in finance and accounting to oversee the company's financial reporting and internal controls.
  • Implement a Code of Ethics: Develop and implement a comprehensive code of ethics that outlines ethical conduct expectations for all employees.
  • Enhance Employee Training: Provide all employees with comprehensive training on internal controls, fraud detection, and ethical conduct.

Technology Implementation:

  • Invest in Advanced Accounting Software: Invest in advanced accounting software that provides real-time financial reporting, automated reconciliation, and robust internal controls.
  • Implement Data Analytics Tools: Utilize data analytics tools to identify potential fraud, analyze financial trends, and improve decision-making.
  • Enhance IT Security: Strengthen IT security measures to protect sensitive data and prevent unauthorized access.

Organizational Structure and Design:

  • Improve Segregation of Duties: Implement clear segregation of duties across all departments to minimize the risk of fraud and error.
  • Establish Clear Lines of Authority: Establish clear lines of authority and reporting relationships to ensure accountability and effective communication.
  • Promote a Culture of Compliance: Foster a culture of compliance by emphasizing the importance of ethical conduct, internal controls, and risk management.

5. Basis of Recommendations

These recommendations are based on a thorough analysis of the Sands' internal control weaknesses, industry best practices, and regulatory requirements. They are consistent with the company's mission to provide exceptional entertainment and hospitality experiences while ensuring the integrity of its operations.

The recommendations consider the following:

  • Core competencies and consistency with mission: The recommendations focus on strengthening internal controls to ensure the company's long-term sustainability and maintain its reputation as a trusted and reliable operator.
  • External customers and internal clients: The recommendations aim to improve the company's financial reporting and risk management to increase investor confidence and enhance the overall experience for both customers and employees.
  • Competitors: The recommendations align with industry best practices and ensure the Sands remains competitive by implementing robust internal controls and enhancing its corporate governance.
  • Attractiveness ' quantitative measures: The recommendations are expected to lead to improved financial performance, reduced risk exposure, and enhanced investor confidence, ultimately contributing to increased profitability and shareholder value.

6. Conclusion

By implementing these recommendations, the Sands Hotel and Casino can significantly strengthen its internal control system, mitigate risks, improve financial reporting, and enhance corporate governance. This will restore investor confidence, improve operational efficiency, and ensure the company's long-term sustainability.

7. Discussion

Other alternatives not selected include:

  • Outsource financial reporting: While outsourcing could provide some expertise, it may not address the underlying issues of internal control and risk management.
  • Minimal changes: Implementing only minimal changes would not be sufficient to address the significant weaknesses identified in the case study.

Key assumptions of the recommendations include:

  • Management commitment: The success of these recommendations hinges on the commitment of the Sands' management team to implement and sustain the changes.
  • Resource allocation: Adequate resources will be allocated to implement the proposed changes, including training, technology, and personnel.
  • Effective communication: Clear and consistent communication will be maintained throughout the implementation process to ensure buy-in from all stakeholders.

8. Next Steps

The following timeline outlines key milestones for implementing the recommendations:

  • Phase 1 (Months 1-3): Conduct a comprehensive risk assessment, develop a risk management framework, and implement initial changes to accounting procedures and policies.
  • Phase 2 (Months 4-6): Implement activity-based costing, enhance financial reporting processes, and strengthen internal controls over financial reporting.
  • Phase 3 (Months 7-9): Implement a robust fraud detection system, enhance IT security, and provide employee training on internal controls and ethical conduct.
  • Phase 4 (Months 10-12): Review and refine the implemented changes, monitor progress, and make adjustments as needed.

By taking these steps, the Sands Hotel and Casino can transform its internal control system into a robust and effective framework, ensuring its continued success and growth.

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Case Description

Describes the controls used in the casino over the blackjack game and cash stocks, and movements of cash. Also describes the results measures available in the casino and their limitations for control purposes.

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