These accounts generally require casinos to obtain basic identification information about the accountholders and to inquire into the kinds of wagering activities in which the customer is likely to engage. Casino employees who monitor customer gaming activity or conduct transactions with customers are in a unique position to recognize transactions and activities that appear to have no legitimate purpose, are not usual for a specific player or type of players, or are not consistent with transactions involving wagering. While reviewing computerized player rating records, an employee determines that a customer frequently purchases chips with currency between $5,000 and $10,000, engages in minimal gaming, and walks away with the chips. Many casinos routinely obtain a great deal of information about their customers through deposit, credit, check cashing, player rating and slot club accounts. Two or more customers each purchase chips with currency in amounts between $3,000 and $10,000, engage in minimal gaming, combine the chips (totaling in excess of $10,000), and one of them redeems the chips for a casino check.
A customer pays off a large credit debt, such as markers or bad checks, of more than $20,000 over a short period of time (e.g., less than one week), through a series of currency transactions, none of which exceeds $10,000 in a gaming day. A customer appears to use a casino account primarily as a temporary repository for funds by making frequent deposits into the account and, within a short period of time (e.g., one to two days), requests money transfers of all but a token amount to domestic or foreign-based bank accounts. This guidance is intended to assist casinos and card clubs1 with the reporting of suspected money laundering, terrorist financing and related financial crimes. In this guidance, the term “casino” is used to refer to casinos, card clubs and other gaming establishments that fall within the BSA and FinCEN’s regulations, unless otherwise noted. A customer using a slot club account card inserts $2,990 of paper money (or an amount just below established thresholds) into a bill acceptor on a slot machine or video lottery terminal (e.g., contemporaneously inserting $5s, $10s and $20s), accumulating credits with minimal or no gaming activity, presses the “cash out” button to obtain a ticket.
A customer, who is a big winner, enlists another individual (who is not a partner of the customer in the gaming activity), to cash out a portion of the chips or tokens won to avoid the filing of a CTRC, IRS Form W-2G or other tax forms. A customer seeks to cash out chips, tickets or tokens in excess of $10,000, but when asked for identification for completing a CTRC, reduces the amount of chips or tokens to be cashed out to less than $10,000. A customer arranges large money transfers out of the country which are paid for by multiple cashier’s checks from different financial institutions in amounts under $10,000. A customer makes large deposits or pays off large markers with multiple instruments (e.g., cashier’s checks, money orders, traveler’s checks, or foreign drafts) in amounts of less than $3,000. A customer makes a large deposit using numerous small denomination bills (e.g., $5s, $10s and $20s); and withdraws it in chips at a table game, engages in minimal gaming, and exchanges remaining chips at a cage for large denomination bills (e.g., $100), a casino check or a money transfer.
A customer transfers funds to a casino for deposit into a front money account in excess of $5,000; and withdraws it in chips at a table game, engages in minimal or no gaming activity, and exchanges remaining chips at a cage for a casino check. A customer draws casino markers (e.g., between $5,000 and $10,000) which he/she uses to purchase chips, engages in minimal or no gaming activity, and then pays off the markers in currency and subsequently redeems the chips for a casino check. Then the customer redeems the tickets for large denomination bills or casino checks with different cage cashiers at different times in a gaming day. The customer then goes to the cage and redeems the remaining chips for currency in an amount that is less than the CTRC reporting threshold. A customer purchases a large amount of chips with currency at a table, engages in minimal gaming, and then redeems the chips for a casino check. A customer receives a race book or sports pool payout in excess of $10,000 and requests currency of less than $10,000 and the balance paid in chips. A customer requests the issuance of casino checks, each less than $3,000, which are made payable to third parties or checks without a specified payee.
