This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here.

So where do you actually work—in one of the hotels or casinos?

Yep, I’m physically located at the Trump Taj Mahal in Atlantic City. Pretty nice.

And you’re chief of compliance. What do you oversee?

I started here on April 1, and basically I was hired solely for the Sarbanes-Oxley review. That’s all I have right now, Sarbanes-Oxley work.

How did you get into the gaming industry in the first place? And how did you fall in league with Trump?

I started in the casino business right out of college, and I started in Atlantic City. I worked at Caesar’s Atlantic and worked for the Trump organization, and then became director of internal audit for Player’s International and moved to southern Illinois for eight years. Then I moved back to Atlantic City two years ago.

The person I report to now is the CFO, Frank McCarthy. I had worked for him before in Atlantic City, so when he conducted a search he knew I was back in town. We started talking, and here I am.

Sarbanes-Oxley aside, the casino industry must be regulated six ways to Sunday. What other compliance issues do you face?

Well, from a Sarbanes-Oxley perspective, it does make things a lot easier since there are so many documented and established accounting and internal controls procedures relating to the casino. It makes it easier to build on that and develop a Sarbanes-Oxley review; there’s already a good foundation for it.

But we are heavily regulated: they’re called the 1945 Regulations, which govern accounting procedures that casinos must follow in Atlantic City. For example, there are regulations on how chips are placed from the casino cage to the tables, or how jackpot payouts are made. Any time there are any transfers of funds on the casino floor, there are documented procedures that must be followed to track that transaction. While all the cash transactions are very volatile because it’s cash moving around, there are a lot of controls involved that make sure funds go from Point A to Point B and are tracked properly.

What’s the oversight structure for your Sarbanes-Oxley compliance?

We have an oversight committee, established about a year ago. It’s the senior financial people from each of the properties (we have a VP of finance at each property), the vice president of IT, the director of internal audit, and myself. And it’s chaired by the CFO. We meet every two weeks.

You’re the point-man for the project. Do you have any other staff working under you at the moment?

Actually, right now it’s basically me. I pretty much have the assistance of the internal audit department and IT, where I can get a lot of the work done through the different departments.

And this is for the entire Trump Hotel & Casino organization, correct?

The project is for all our properties. Right now we have three properties in Atlantic City, and a riverboat in Buffington Harbor, Ind. We also have a management contract for a casino in California, but we don’t have any Sarbanes-Oxley responsibility for that.

Lots of compliance officers admit to us they underestimated the effort Sarbanes-Oxley would require. What has Trump’s experience been?

For one thing, we’re a 2005 company; that gives us more time for the process. Since I’ve come on in April, I’ve tried to put together a pretty regimented schedule of what areas I wanted to examine at what time—and we’ve pretty much stuck with the schedule. With limited resources, I think it’s important to create that plan. It was the first thing I did when I came on board.

I also prepared a risk assessment for each of the four properties, basically reviewing the balance sheets and income statements for the properties. We took the risk assessments and built from that for the documentation processes.

So what is the strategy or timetable you plan to follow?

We’re doing fairly well. The bulk of the documentation is complete on major areas in one property, the Taj; we’ve also gone into doing our own testing of documentation. Our game plan is to come to a point where our outside auditors can start doing their preliminary testing and really review our one property here at the Taj. Then we will go forward to the other properties.

The way things are structured here, the properties operate independently but we have a lot of the same systems. We have identical accounting and internal-control procedures. So that makes it a lot easier to focus on one property and then work on all the others.

Some companies do take the Sarbanes-Oxley opportunity to install entirely new IT systems for controls. You don’t see that as necessary, since everyone is running from the same playbook?

I think so. And again, the bulk of the systems are here at the Taj, so it’s much easier for me to review. For example, all four properties run the same payroll system. So when I review the controls for one system, in effect I’ve looked at all four.

We haven’t really put anything else in place. We’re using existing systems. As far as documentation, we have an Access spreadsheet that we’re using. Basically it’s a template that Ernst & Young uses, and we’ve adopted that as our model. Supplementing that, we have our documentation and our flowcharts for each of the areas.

No outside consultants helping you along right now?

Not at the moment. It’s possible that will change, but we’re trying to do as much as we can in-house and so far it’s been working.

Trump did file a reorganization plan in bankruptcy court this summer, where new investors provided a cash infusion to keep the company afloat. Does that have any consequence for the Sarbanes-Oxley compliance?

No, it really doesn’t.

What are your top compliance priorities for the next 12 months or so?

Well, I think one of the challenges down the road is that three of our properties are here in Atlantic City, but the other property is in Indiana. That makes it a little more difficult, having the distance there, to get all the documentation. It’s more of a free-standing property; the other three are pretty-well integrated with each other.

The other challenge is making sure the IT systems are reviewed. We have a lot of systems that operate on the casino floor, so it’s making sure that the documentation is in place and the internal controls are tested.

How do you the finance people communicate with “them” the IT people, to ensure everyone has all the knowledge of systems and controls that the project needs?

For each area I review, I try to integrate the IT portion in that review into the documentation. I work closely with the IT department, basically to walk through the systems with them. Where they have more knowledge of how the systems operate, I can sit down with the IT people and they can show me how it works.

Is there a significant learning curve, explaining to people what Sarbanes-Oxley is and that this is a permanent change rather than a single project?

It comes down to the department. Most of the finance areas are pretty comfortable with it, but when you start reviewing areas like marketing or casino floor operations—they don’t understand exactly what you’re doing. But everyone is cooperative, so it’s been a good process.

And we’re suckers for fame here at CW, so we have to ask: How often do you see The Donald?

He’s here from time to time. Since I’ve been here, I’ve seen him a few times. My office is across the way from the helipad, so I usually see when his helicopter is coming in.

Thanks, Joe.

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