Overview
During the audit period, the Lottery did not enforce its own policy that was designed to ensure that sales agents complied with regulations regarding the sale of lottery products to minors. Specifically, the Lottery did not employ minors to train how to appropriately conduct sting operations by attempting to purchase lottery products from sales agents. Therefore, the Lottery did not conduct sting operations on a random sample of sales agents in different sales regions, as required by Part A of Section V of the Lottery's “Monitoring & Testing—Sale to Minors” policy.
The absence of monitoring and testing of sales agents’ compliance with the Lottery’s policy restricts its ability to effectively monitor the sale of lottery products to minors. This hampers the Lottery’s efforts to safeguard the public and promote responsible gaming behavior.
Authoritative Guidance
According to Part A of Section V of the Lottery's “Monitoring & Testing—Sale to Minors” policy, issued March 2013,
Assistant Executive Director will:
- Implement a program to monitor and test Agents for compliance with this policy prohibiting the sale of Lottery products to minors. The program must regularly monitor and test a group of Agents, randomly selected from each sales region through a computer generated program, which is sufficiently large in number to achieve a statistically acceptable result. The program must also re-monitor and re-test those Agents who have not demonstrated compliance with this policy.
- Work with Human Resources to hire a minor or minors to assist with the monitoring and testing program.
Reasons for Issue
Lottery officials stated that other policies and testing have taken precedent over its “Monitoring & Testing—Sale to Minors” policy. They also stated that with the change of Compliance Department management, this policy was no longer implemented, despite it not being withdrawn. Additionally, the Lottery reported that it has not reviewed and updated this policy since 2013.
Recommendations
- The Lottery should develop monitoring controls to ensure that sales agents comply with laws, regulations, and policies regarding the sale of Lottery products to minors.
- The Lottery should review, update, and reimplement its “Monitoring & Testing—Sales to Minors” policy.
Auditee’s Response
- The [Massachusetts State Lottery Commission] takes meaningful steps to keep Lottery tickets out of the hands of minors through its in-house training program, onsite compliance reviews and having sales agents sign a code of conduct with the provision of prohibiting sales to minors. When the Lottery receives a complaint or is made aware that one of its agents is or has sold Lottery product to a minor, the Compliance & Security Department investigates the matter promptly and imposes licensing suspensions in accordance with Lottery regulations. The Lottery does not monitor and test its sales agents per the 2013 Sale to Minors policy. The Lottery considers this policy no longer applicable due to the extraordinary resources needed to implement it.
Auditor’s Reply
We acknowledge that the Lottery provides training, conducts compliance reviews, and responds to complaints; however, these efforts do not align with the monitoring and testing required by its “Monitoring and Testing—Sales to Minors” policy that was in place during the audit period. If this policy is no longer applicable, it should either be officially withdrawn or revised to reflect current practices related to monitoring sales to minors.
| Date published: | November 26, 2025 |
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