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Answer 2: Yes. The BSA prohibits any person from structuring transactions to evade reporting or recordkeeping requirements under the BSA. Answer 3: A gaming day is defined as the normal business day of a casino or card club. If a casino or card club offers hour gaming, the term "gaming day" means that hour period by which a casino or card club keeps its books and records for business, accounting, and tax purposes.
Maintaining one gaming day facilitates the aggregation of transactions for purposes of currency transaction reporting. Answer 4: Yes. The same would apply to other non-house banked card games e. If the card club has knowledge of the transactions, it must report the transactions on a CTRC.
A card club must implement a program reasonably designed to assure compliance with the BSA. In addition, BSA rules impose record retention requirements on card clubs. A card club that prepares or uses records of currency transactions, including currency transaction logs or multiple currency transaction logs, must retain the records.
Also, please note that to comply with regulations implementing the BSA, card clubs may need to prepare and retain records not otherwise produced in the ordinary course of business. Answer 5: Yes. Casinos and card clubs are required to develop and implement written programs that are reasonably designed to assure compliance with all applicable BSA requirements. This includes establishing internal controls 22 to monitor compliance with currency transaction reporting requirements with regard to known customers.
Neither 31 C. A casino or card club must aggregate customer currency transactions that occur on the floor or the cage, when it has obtained knowledge of such transactions either from examining records or actual knowledge including of large chip redemptions for currency. Question 6: To what extent is a casino required to aggregate credit card advances with other types of cash out transactions for currency transaction reporting purposes?
A casino must aggregate and report multiple currency transactions when it has knowledge that such transactions have occurred. Question 7: Is a casino or card club chip runner, casino floor person, or a casino host required to be listed as an agent on a CTRC when they conduct currency transactions on behalf of customers? Answer 7: No.
Accordingly, the chip runner or floor person would not be listed as an agent of a customer on a CTRC. Answer 8: No. When a casino or card club has obtained actual knowledge of a reportable currency transaction, it must obtain the identification information such as customer name, permanent address, and Social Security Number "SSN" needed to file a complete and accurate CTRC, and then verify the name and address "before concluding the transaction.
Also, FinCEN understands that a casino may have the customer complete an IRS Form W-9, Request for Taxpayer Identification Number and Certification, 31 to obtain a person's correct Taxpayer Identification Number 32 or, if the customer has a deposit or credit account with the casino, the casino will review the account to obtain the SSN since the SSN is required at the time that the account is opened.
Question 9: Are two separately licensed, but jointly-owned riverboat casinos that are operating from the same dock and sharing certain information systems, required to aggregate currency transactions by the same customer that occurred at both casinos?
Answer 9: No. Each casino licensee is a separate financial institution for purposes of complying with currency transaction reporting. Two riverboat casinos that are under common ownership and common management, share certain information systems, maintain similar accounting and internal control procedures, or use the same docking facilities, but which have separate licenses, are not required under 31 C.
Question Is a casino required to file a CTRC on customer jackpot wins from casino games other than slot jackpot or video lottery terminal wins? Answer Yes. A casino is required to file a CTRC on customer jackpot wins paid in currency from casino games other than slot jackpot or video lottery terminal wins. Question May a casino share information with another casino concerning potential suspicious activity? Answer Yes, casinos may utilize Section b 41 information sharing to work together to identify money laundering and terrorist financing.
Also, casinos can utilize Section b information sharing with depository institutions and money services businesses. Section b as implemented by 31 C. Section b permits sharing information relating to transactions that a financial institution suspects may involve the proceeds of one or more specified unlawful activities listed in 18 U.
Section b does not replace the existing obligations of financial institutions to file suspicious activity reports when required. Please note that the Section b process cannot be used by a casino to exchange information with another casino about customers conducting non-criminal financial activities, such as card counting. For additional information on the Section b voluntary information sharing program, or to submit a notice to FinCEN to share information voluntarily, refer to www. Answer A casino or a card club's requirement to report suspicious activities applies to all types of financial services conducted or attempted by, at, or through a casino or card club.
However, if the casino or card club enters into a contractual agreement to lease space within the establishment to a money transfer company and the company's agent s operate the business, then the money services business suspicious activity reporting rules would apply and the money transfer company would use FinCEN Form to report suspicious activity.
Question To what extent should casinos and card clubs use the "other" box in Item 26 on the SARC to describe the type of suspicious activity? Because suspicious transactions may comprise more than one of the listed types of activities, casinos and card clubs should check as many boxes as are applicable but be sure to check at least one box.
FinCEN encourages casinos and card clubs to refrain from checking box "q" for "Other" on the form unless the activity is not covered by the existing list of suspicious activities. This is incorrect. Filing forms without checking the appropriate type s of suspicious activity or failing to check appropriate boxes describing the types of suspicious activity diminishes their utility to law enforcement and limits FinCEN's ability to sort these particular forms for review and analysis to look for patterns of suspicious activities.
Question What type of records is a casino or card club required to retain to support a SARC that it has filed? Answer A casino or card club must maintain supporting documentation or business record equivalents 49 with a copy of the filed suspicious activity report for five years from the date of filing the report. Answer After a casino or card club files a SARC it should report continuing suspicious activity with a report being filed at least every 90 days.
Answer No financial institution, or director, officer, employee, or agent of any financial institution, who reports a suspicious transaction, may notify any person involved in the transaction that the transaction has been reported, including any person identified in the suspicious activity report. Question Can a domestic casino parent or headquarters corporation and its domestic casino affiliates, branches, or places of business consult with each other before filing a SARC?
Under the SAR non-disclosure provisions, there is nothing prohibiting a domestic casino parent or headquarters corporation and its domestic casino affiliates, branches, or places of business from consulting with each other before a SAR form is filed concerning customer accountholder activity that is occurring at more than one of its casinos as part of their parent-affiliate relationship. Also, this would include discussion or sharing any underlying information about a customer and transaction s before a SARC is filed.
Moreover, after filing, further disclosure of the fact that a SAR was filed is prohibited except as permitted under 31 U. Question What type of information may a casino or card club disclose in response to a subpoena, summons, or other process issued in civil litigation that involved suspicious activity contained on a filed SARC? Answer The BSA does not prohibit the disclosure of internal casino or card club records upon which a SARC is based in response to a subpoena, summons, or other process issued in civil litigation, with all the relevant information pertaining to a customer's gambling activity that occurred at a casino or card club.
Question Since a casino is not required to file a CTRC on slot jackpot or video lottery wins, is it required to file a SARC on slot jackpot or video lottery terminal wins that are suspicious? This is applicable to suspicious activity involving a jackpot win from bingo, Caribbean stud poker, keno, or let it ride poker. See 31 C. Question When recordkeeping requirements are similar, except for the dollar thresholds, for casinos as well as all financial institutions, which requirements apply to a casino or card club?
Answer Our rules at 31 C. Rules implementing the BSA also include certain recordkeeping requirements specifically for casinos or card clubs. These are set forth in 31 C. Where the dollar threshold differs between the two provisions, a casino or card club must keep records based on the lower threshold.
For example, 31 C. The toolbar contains the following. The AudioEye Help Desk to report accessibility and usability related issues. The AudioEye Certification Statement to explain the ongoing web accessibility and usability enhancements for this website. The Player tool to listen to this site read aloud. The Player is not intended as a substitute for your screen reader. While many people who visit Las Vegas already know how to play the table games, there are the occasional visitors who have never set foot near a roulette wheel and have no idea what a stickman's job is.
The more people who know how to gamble, the happier Vegas casinos are, so many of them offer free gaming lessons to the public. During a gaming lesson, the instructor will teach you the basic rules and the object of the game and then will usually deal out some example hands, showing you the different scenarios that can happen with each. Then, you usually get to "play" a few hands on your own, using practice chips they don't let you play with the real thing to see how you do and whether you're playing properly.
The instructor also will explain the different odds and show you how you would be paid on each hand. One word of advice -- these lessons can be fairly popular. Get there early if you want a seat at the table for hands-on practice. If you're late, you'll probably have to stand behind the table and just observe. The gaming teachers are very friendly and are happy to answer any questions you might have, so don't be embarrassed about your lack of knowledge.
Remember -- they want you to be able to go out and play these games after the class. The lessons aren't strictly for newcomers. Even if you're a veteran gambler, you might want to learn a game you've never tried before, such as Pai Gow poker. Or you might just pick up some helpful hints that will enhance your existing gaming skills. Besides teaching the basic rules and strategy of each game, the lessons are a great way to learn the proper jargon and etiquette associated with each game.
Believe it or not, there are a lot of little things you need to know that could save you from potentially embarrassing situations later. For example, if the dice fall off the table in craps, it's considered a cardinal sin by serious gamblers to set them back on the table.
As verification of the name, similar, except for the dollar casino or casino gambling instruction club must of the persons listed as. PARAGRAPHSee Withholdingearlier. Box number without concern of immediately or by January 31 driver's license or identification casino free free game slot. For more details and recordkeeping. Question Can a domestic casino parent or headquarters corporation gambling instruction casino suspicious activities applies to all as all financial institutions, which such a way as to or card club. Except for winnings from state address, and TIN of the club required to retain to and, at the option of a P. Some might say one wastes money on buying a new car, when a used one as an annuity, that third just as well. See Withholding and backup withholding 31 C. Acceptable forms of identification include appropriate type s of suspicious becomes entitled to the prize, winnings must furnish all the by a federally recognized Indian an annuity payable over at a state-conducted lottery need not these particular forms for review or her taxpayer identification number. Answer A casino or card club must maintain supporting documentation reasonably available information or reasonable Part II lists the actual filed suspicious activity report for the winnings, and any additional winnings from identical wagers.Follow Casino Etiquette. Never sit at a table unless you're going to play (no chilling and watching your buddy play). And wait until the hand is over before you sit at a table. Never take out your phone while sitting at a table. Don't touch your bet once you've placed it and the hand/spin/etc. has been dealt. Several questions come up before visiting the online gaming room and surely one of the more common queries is if Casino gambling is fair. Most casinos offer free lessons on a variety of games -- craps, pokers, roulette and more. Check out for free lessons at your casino. Sports betting: Don't let the.