casino regulations under the bank secrecy act


  • [2] Transaction reporting Currency transactions that occur within a single Gaming Day (the normal 24-hour period that any casino uses for accounting and business reporting),
    whether the currency is paid into the casino, paid out, or exchanged (in the case of foreign currency exchanges), in excess of $10,000 requires the completion of a Currency Transaction Report (CTR, FinCEN Form 112) and must contain enough
    information to accurately identify the individual(s) transacting the currency.

  • Structuring[edit] Because the $10,000 per gaming day CTR threshold is part of the Bank Secrecy Act, a criminal may seek to evade being recorded on a CTR by breaking a transaction
    over $10,000 into multiple smaller transactions, which is known as structuring.

  • And, while it may be possible to break up $12,000 into 20 individual transactions of $600 each, casino personnel also maintains awareness of this tactic and would likely detect
    the numerous trips to the cage to perform similar transactions.

  • Minimal gaming[edit] Another type of suspicious activity is related to money laundering, where a casino patron may put large amounts of money in play, but gambles very little
    before cashing out.

  • Again, criminals (including those interested in tax evasion) may break up their transactions into several, smaller transactions to avoid detection.

  • Agents cashing out chips or making currency transactions on behalf of one another are also popular examples of agent activity.

  • However, because most casinos track transactions of $4,000 (and lower), structuring this $12,000 transaction into three, smaller transactions would not prevent a CTR from
    being filed.

  • Because multiple transactions are aggregated for the purpose of Title 31 reporting, casinos create tracking programs to identify large transactions and automatically aggregate
    them in real time to ensure that they are compliant with the regulations.

  • a husband cashing out his wife’s slot vouchers so she can continue to play), agent activity is highly suspicious because it allows individuals to structure their transactions
    below the $10,000 to avoid being documented to the IRS.

  • [1] Although Title 31, also known as the Bank Secrecy Act, was originally focused on financial institutions, criminal use of banking services located within casinos created
    a need for additional regulations that were specific to casinos.

  • All parties involved in agent activity must submit proper identification and complete the required IRS forms when their COMBINED transactions reach over $10,000 in a gaming

  • Because $10,400 was paid out in cash to a single individual in a single Gaming Day, a CTR must be filed by the casino to report the Cash Out transaction, because it is above
    the $10,000 threshold.

  • If the casinos did not track multiple transactions, the individual might be able to circumvent the reporting of their transactions.

  • Single and multiple currency transactions in excess of $10,000 (in a single Gaming Day) are reported to the IRS.

  • Since agents handle the same bankroll, they essentially become entities and their transactions must be recorded together.

  • Casinos in the United States which generate more than $1,000,000 in annual gaming revenues are required to report certain currency transactions to assist the Financial Crimes
    Enforcement Network (FinCEN) of the Internal Revenue Service (IRS) in uncovering money laundering activities and other financial crimes (including terrorist financing).


Works Cited

[‘Products, FraudFighter. “Title 31 of the Bank Secrecy Act: Casino Compliance | Regulatory Compliance Management Education”. Retrieved 2021-09-19.
2. ^ United States Senate Committee on Indian Affairs (November 17, 2011). “The
Future of Internet Gaming: What’s at stake for tribes?”. One Hundred Twelfth Congress First Session.
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