Fighting Fraud a Collaborative Effort

Partner Profile:
MGM Resorts International 

According to Heidi Sealy, CFE, Senior VP of the Fraud Control Group at MGM Resorts International, recognizing that fraud exists in almost any business environment is a crucial first step to actively managing fraud within an organization. "Historically fraud has largely been dealt with on a reactive case by case basis. However, in large organizations it is vital to assess fraud risk across all business operations and proactively put controls in place to prevent fraud from occurring," Sealy said. "It is also important to create review processes to quickly detect fraud when it does happen, so it can be eliminated and prevented in the future." 

Sealy sees fighting fraud in a large organization as a collaborative effort. MGM Resorts International grew through acquisition when MGM purchased Mirage Resorts in 2000 and then Mandalay Bay Group in 2005. With the development and opening of City Center in 2008, the company grew to 16 domestic casinos with 62,000 employees.  "The workplace cultures and policies were very different at each of the individual companies that merged together under one management team," Sealy said. "A significant portion of our operations were siloed by property, making it difficult to support from a central location. MGM restructured in 2010, resulting in a more receptive environment for corporate support functions." This was also about the time that Sealy began to see the need for a way to identify and acknowledge the fraud that had been happening at each of the individual properties and address it for the company as a whole.   

Internal collaboration with other key departments is imperative to MGM's Fraud Control success. There are daily interactions with internal audit, surveillance, security, legal, compliance and human resources. Strong communications between these departments is essential to MGM's successful fraud efforts, so a significant amount of time and resources are devoted to ensuring open, timely lines of communication containing accurate and relevant information. MGM has also established strong communication ties and daily interactions with outside entities such as gaming regulators and enforcement agencies.

"We recently reviewed our Fraud Control program at a high level and identified what we believe is a real opportunity for us to improve our efforts by establishing relationships and information sharing with other large corporations fighting fraud in their own environments," Sealy said. "We turned to the ACFE for advice and direction. Our decision to join the ACFE's Corporate Alliance came from the highest levels of our organization. Management wants to ensure that MGM takes a proactive, visible and vocal role in fighting fraud in the workplace, both within our organization and elsewhere. Joining a program like the Corporate Alliance to open a dialogue with other corporations experiencing similar frauds and sharing non-competitive information is a real win/win situation. We are eager to speak with other organizations on an extended basis about ways to prevent, detect and investigate fraud activities."

Sealy believes that one of the biggest benefits to joining the Corporate Alliance program, on top of savings on training and exclusive resources, is the networking that can happen between corporations publicly taking a stand against fraud. "The biggest bang for our buck is having an open dialogue with companies that face the same challenges we face. We all benefit when we come together in a variety of different manners." Along with joining the Corporate Alliance program, MGM recently launched hospitality industry roundtable conference call meetings to discuss the latest trends and frauds affecting the industry. "Very little of what we do on my team is competitive in nature," Sealy said. "The more we can communicate and share relevant information across companies, the more effective we will all be in our fraud fighting efforts.

Sealy and her team are just one of many large corporations that have signed up to partner with the ACFE Corporate Alliance program and take a visible stand against fraud. For more information about the program and to read the rest of the profile, visit