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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 What are the civil penalties for non-compliance with BSA recordkeeping and reporting requirements? 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? This is incorrect. 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. 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? If a customer's state driver's license or identification card contains a P. 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. 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.

This document provides guidance interpreting the requirements of the Bank Secrecy Act "BSA" regulations 1 as they apply to the casino and card club industries in the United States. For example, 31 C. Question What type of information may a click here 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 8: No. Postal Service, and ZIP code, including any apartment number or suite fin de mission casino and road or road number associated with a permanent address to comply with these recordkeeping requirements.

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? Fin de mission casino 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. Box number unless the more info has no street address. Accordingly, the chip runner or floor person would not be listed as an agent of a customer on a CTRC.

Answer Yes. Answer 3: A gaming day is defined as the normal business day of a white horse pass phoenix or card club.

Where the dollar threshold differs between the two provisions, a casino or card club must keep records based on the lower threshold. 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.

Answer To comply with 31 C. If the card club has knowledge of the transactions, it must report the transactions on a CTRC. Question How can a casino's compliance committee help to assure that a casino complies with the BSA?

Section b as implemented by 31 C. 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. A card club casino soaring motels cheap near eagle implement a program reasonably designed to assure compliance with the BSA.

In addition, BSA rules impose record retention requirements on card clubs. 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.

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. 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?

Under the SAR non-disclosure provisions, there is nothing prohibiting a domestic casino parent or headquarters corporation and its domestic casino fin de mission casino, 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.

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. In addition, FinCEN may seek civil money penalties up to the amount of transaction for structuring, attempting to structure, or assisting in structuring transactions.

Question May a casino share information with another casino concerning potential suspicious activity? Answer Our rules at 31 C. 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.

Question Must a casino's anti-money laundering compliance officer limit his duties to BSA compliance matters? Answer 1: A Nevada slot route operator is a gaming licensee who, pursuant to a participation agreement, owns and maintains slot machines at three or more business establishments.

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.

The same would apply to other non-house banked card games e. These civil sanctions are for willful violations 63 and may be applied to any casino or card club that is subject to the BSA, or to any partner, director, officer, or employee of such gaming operations.

Answer 9: No. As a reminder, scanned or microfilmed player rating records must be retained for 5 years and filed or fin de mission casino in such a way as fin de mission casino be accessible within a reasonable period of time. A casino must aggregate and report multiple currency transactions when it has knowledge that such transactions have occurred.

This includes establishing internal controls 22 to monitor compliance with currency transaction reporting requirements with regard to known customers. Also, this would include discussion or sharing any underlying information about a customer and transaction s before a SARC is filed.

Part This would include, among other customer records, records prepared or used to monitor a customer's fin de mission casino activity e.

These are set forth in 31 C. 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. 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?

Question Does a casino or card club have to record a customer's permanent address for BSA recordkeeping requirements or is a P. Section A: 31 C. The business supply houston are owned and operated by other persons.

The BSA requires the retention of the source records either the originals or microfilm version, or other copies or reproductions of the documents of all records required to caesars page retained by 31 C.

Answer 4: Yes. FinCEN understands that casinos establish BSA compliance committees as an executive level safeguard to ensure that a casino complies with all applicable laws, regulations, and guidance in a reasonable manner.

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.

The BSA prohibits any person from structuring transactions to evade reporting or recordkeeping requirements under the BSA. Also, casinos can utilize Section b information sharing with depository institutions and money services businesses.

Therefore, when a casino or card club complies with 31 C. 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.

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.

Answer Casinos and card clubs are not required under the BSA to establish compliance committees in all instances. This is applicable to suspicious activity involving a jackpot win from bingo, Caribbean stud poker, keno, or let it ride poker.

Casinos and card clubs are required to develop and implement written programs that are reasonably designed to assure compliance with all applicable BSA requirements.

We additionally published frequently asked questions for casinos and card clubs as FING on November 14, Casinos and card clubs may continue to rely on the guidance contained in FING, which has not been incorporated into this publication.

Rules implementing the BSA also include certain recordkeeping requirements specifically for casinos or card clubs. 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?

Section b does not replace the existing obligations of financial institutions to file suspicious activity reports when required.

A card club that prepares or uses records of currency transactions, including currency transaction logs or multiple currency transaction logs, must retain the records. Answer No. 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?

Each casino licensee is a separate https://list.spinslotsmoney.site/casino/proposed-wareham-casino-location.html institution for purposes of complying with currency transaction reporting.

Although the BSA requires financial institutions, here casinos or card clubs, to designate an individual or individuals e. Fin de mission casino 5: Yes. Maintaining one gaming day facilitates the aggregation of transactions for casinos near plano of currency transaction reporting.

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. A Nevada "nonrestricted license" or "nonrestricted operation" also includes, among other things: i ".

A casino or card club is required to use all reasonably available information or reasonable alternatives to obtain the needed information to be in compliance with the BSA and should not enter a P. Neither 31 C. Moreover, after filing, further disclosure of the fact that a SAR was filed is prohibited except as permitted under 31 U. See 31 C. Answer Yes, casinos may utilize Section b 41 information sharing to work together to identify money laundering and terrorist financing. Nonetheless, there may be instances in which the risk confronting a casino or a card club would require establishing a BSA compliance committee. Question If a casino scans or microfilms its player rating records, is it required also to keep the paper copy of the record? Question What type of records is a casino or card club required to retain to support a SARC that it has filed? Each casino and card club should conduct a risk-based analysis of its business e. 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. Box number without concern of non-compliance with the above BSA recordkeeping requirements. Answer 2: Yes. 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. Also, although the requirements in 31 C. Box number acceptable when it appears on a customer's state driver's license or identification card? 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.