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Frequently Asked Questions Casino Record keeping, Reporting, and Compliance Program Requirements FinCEN.
We additionally published frequently asked questions for casinos and card clubs as FIN-2007-G005 on November 14, 2007.
Casinos and card clubs may continue to rely on the guidance contained in FIN-2007-G005, which has not been incorporated into this publication.
Section A: 31 C.
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.
The business establishments are owned and operated by other persons.
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 tuscany suites casino day of a casino or card club.
If a casino or card club offers 24-hour gaming, the term "gaming day" means that 24-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.
Question 4: Is a card club required to file FinCEN Form 103, Currency Transaction Report by Casinos "CTRC"for customer currency buy-ins at poker games?
The same would apply to other non-house banked card games source />If the card club has knowledge of the transactions, it must report the transactions on a CTRC.
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.
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.
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 casino space requirements chip redemptions for currency.
A casino must aggregate and report multiple currency transactions when it has knowledge that such transactions have occurred.
Question 7: Is little six casino shuttle 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?
Accordingly, the chip runner or floor person would not be listed as an agent of a customer on a CTRC.
Question 8: When a customer refuses to provide a Social Security Number for completing a CTRC, can a casino or card club write "Refused" in Item 7 of the CTRC?
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.
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.
A casino is required to file a CTRC on customer jackpot wins paid in currency article source casino games other than slot jackpot or video lottery terminal wins.
Section C: 31 C.
Answer 11: Yes, casinos may utilize Section 314 b 41 information sharing to work together to identify money laundering and terrorist financing.
Also, casinos can utilize Section 314 b information sharing with depository institutions and money services businesses.
Section 314 b as implemented by 31 C.
Section 314 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.
§§ 1956 and 1957, which include an array of fraudulent and other criminal activities.
Please note that the Section 314 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, please note that the process cannot be used to share a copy of a filed FinCEN Form 102, Suspicious Activity Report by Casinos and Card Clubs "SARC" or the fact that it was filed, with another consider, calder casino miami join institution.
For additional information on the Section 314 b voluntary information sharing program, or to submit a notice to FinCEN to share information voluntarily, refer to www.
Question 12: Is a casino or card club required to file a SARC, or FinCEN Form 109, Suspicious Activity Report by Money Service Business SAR-MSBfor suspicious money transfers or wire transfers that it receives or sends?
Answer 12: 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 109 to report suspicious activity.
Answer 13: Item 26 on the SARC contains a list of 16 specific types 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 elgin in biggest casino activity is not covered by the existing list of suspicious activities.
FinCEN understands that some casinos and card clubs may go here mistakenly interpreted box "q", "Other Describe in Part VI " to mean that to complete the SARC's "Narrative," you must click at this page this box, since it asks a filer to describe the suspicious activity in Part VI.
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 see more these particular forms for review and analysis to look for patterns of suspicious activities.
Question 14: What type of records is a casino or card club required to retain to support a SARC that it has filed?
Answer 14: 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 15: 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 16: What does the SAR non-disclosure provision mean to a casino or card club that has filed a SARC?
Answer 16: No see more 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.
Moreover, a filed SARC, as well as information that would reveal the existence of a SARC including any document, memorandum, record, log, or work papers that references a SARC must be treated as confidential.
Question 17: Can a domestic casino parent or headquarters corporation and its domestic casino affiliates, branches, or places casino space requirements 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, casino space requirements 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 18: 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 18: 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.
For assistance with specific requests, please contact FinCEN's Office of Chief Counsel at 703 905-3590.
Question 19: 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.
The filing requirements pertaining to: i IRS Form W-2G, Certain Gambling Winnings; ii IRS Form 1042-S, Foreign Person's U.
Source Income Subject to Withholding; or iii IRS Forms 1099-Misc, Miscellaneous Income e.
Section D: 31 C.
Answer 20: 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.
Also, although the requirements in 31 C.
Therefore, when a casino or card club complies with 31 C.
Question 21: If a casino scans or microfilms its player rating records, is it required also to keep the paper copy of the record?
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 be retained by 31 C.
This would include, among other customer records, records prepared or used to monitor a customer's gaming activity e.
As a reminder, scanned or microfilmed player rating records must be retained for 5 years and filed or stored in such a way as to be accessible within a reasonable period of time.
Question 22: Does a casino or card club have to record a customer's permanent address for BSA recordkeeping requirements or is a P.
Box number acceptable when it appears on a customer's state driver's license or identification card?
Answer 22: To comply with 31 C.
Postal Service, and ZIP code, including any apartment number or suite number and road or road number associated with a permanent address to comply with these recordkeeping requirements.
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.
Box number unless the customer has no street address.
If a customer's state driver's license or identification card contains a P.
Box number without concern of non-compliance with the above BSA recordkeeping requirements.
Section E: 31 C.
Although the BSA requires financial institutions, including casinos or card clubs, to designate an individual or individuals e.
Each casino and card club should conduct a risk-based analysis of its business e.
Question 24: How can a casino's compliance committee help to assure that a casino complies with the BSA?
Answer 24: Casinos and card clubs are not required under the BSA to establish compliance committees in all instances.
Nonetheless, there may be instances in which the risk confronting a casino or a card more info would require establishing a BSA compliance committee.
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.
In addition, FinCEN may pump pure oxygen civil money penalties up to the amount of transaction for structuring, attempting to structure, or assisting in structuring transactions.
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.
Questions or comments regarding the contents of this Guidance should be addressed to the FinCEN Regulatory Helpline at 800-949-2732.
A Here "nonrestricted license" or "nonrestricted operation" also includes, among other things: i ".
The party that holds a "nonrestrictive license" and operates the slot machines pursuant to a participation agreement would be the operator of a casino.
See Nevada Revised Statute § 463.
Nevada licenses gaming activity separately at each location.
See Nevada Gaming Commission Regulation 3.
If a Nevada slot route operator is not operating a casino for purposes of our rules, but qualifies as a check casher, or currency dealer or exchanger, as those terms are defined in 31 C.
The negotiable instruments are treated as currency if they are received in a "designated reporting transaction" or used in an attempt to avoid the Form 8300 requirement.
Designated reporting transactions include the retail sale of consumer durables, collectibles, or travel or entertainment activities.
Also, please note that these gambling establishments maybe subject to FinCEN Form 105, Report of International Transportation of Currency and Monetary Instruments "CMIR" as well as Treasury Form TD F 90-22.
Structuring would include attempts to cause Form 8300 not to be filed, or to file a false or incomplete form.
The filer can check item 1b on the Form 8300 to report the structuring.
In addition, it can be checked if there is an indication of possible illegal activity with the transaction.
A buy-in can occur in cash, credit or as a deposit withdrawal.
Games may include California Blackjack, Pai Gow Poker, Pai Gow Tiles, and Super Pan.
Also, an effective BSA internal control will include, in many instances, the creation and retention of records, including those not otherwise produced in the ordinary course of business.
As discussed in Question and Answer 16, a casino must implement procedures reasonably designed to assure the detection and proper reporting of suspicious transactions.
For amounts above that general threshold, an ATM machine prints out vouchers that customers may take to a cage for payment, insert into a slot machine to play, or take to a kiosk machine for dispensing currency.
Also know as a casino "rater.
Duties include assisting in the opening of deposit and credit accounts for customers, and issuing complimentary gifts and services to customers to induce their continued patronage.
Since an ITIN is not acceptable https://reliance-pw.ru/casino/genting-casino-southend-address.html a primary means of identification for purposes of completing Items 14 and 28 on the CTRC, FinCEN will discuss it in the next set of casino frequently asked questions.
Information that could point to the need for a SARC may include a customer providing a false SSN in the past, refusing to provide a SSN or not providing it within the filing period for the CTRC.
§ 2701 et seq.
Therefore, a tribal government may own more than one tribal casino in the same state, but each casino that is separately licensed by the tribal government or the tribal gaming commission would be considered a separately authorized gaming establishment for purposes of currency transaction reporting, even when the casinos have the same Taxpayer Identification Number for purposes of Title 26.
FinCEN recognizes that even for two casinos https://reliance-pw.ru/casino/taxes-on-casinos.html automated data processing systems and programs that are closely integrated, that for an unknown customer that lacks a casino deposit i.
Casinos and casino space requirements clubs should avoid checking "Other" to complete the SARC's Narrative unless the type of suspicious activity that occurred is not listed in Item 26 see FinCEN Form 102, Instructions, Item 26.
Player rating and slot club accounts track gaming activity and serve as a marketing tool to: i identify frequent customers as well as higher dollar players, ii encourage continued patronage, and iii ensure that complementaries are awarded on a cost-effective basis.
Casinos utilize internal controls to help to ensure accountability for customers using player rating and slot club account cards.
A customer's computerized player rating or slot club account record typically contains a customer's name, permanent address, date of birth, sometimes other identification information e.
See SARC, Item 22.
FinCEN proposed amendments to 31 C.
Readers of this guidance should consult that rule, when finalized, for more specific information regarding the appropriate parties to whom a SARC may be provided.
Therefore, since a casino records information on extensions of credit, for example, it must ensure that the records are complete pursuant to 31 C.
A casino's BSA compliance officer is usually a member of such a committee.
A BSA compliance committee may need to schedule regular meetings to establish and monitor a risk-based approach to its business e.
§§ 5320 - 5322, and 5324;and 31 C.

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Japan floats minimum integrated casino resort space requirements - reliance-pw.ru - Gambling News Magazine
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Japan floats minimum integrated casino resort space requirements - f88Casino.
Large footprints: According to a report from casino space requirements an earlier story from the Kyodo news service, officials have remarkable, mashpee casino update think would mandate every one of the prospective facilities offer at least 1,076,391 sq ft of hotel accommodation as well as some 1,291,669 sq ft of meeting space capable of holding at casino space requirements 6,000 people.
In addition, the suggested meeting space provision would purportedly result in the three venues offering more such space than the 1,022,571 sq ft Tokyo Big Site and 5,000-capacity venues in Yokohama and.
Surprising size: Minimum size proposals have come as something of a shock as it was initially thought the government would opt for smaller footprints for the coming see more casino resorts including one regional facility required to feature only a 645,834 sq ft convention center capable of holding approximately 3,000 visitors.
Budget-busting possibility: -headquartered is said to be a leading suitor for one of the coming Japanese integrated casino resort licensees and it earlier mentioned that it would be willing to spend in order to construct such a gambling-friendly facility.
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