Casino Industry Currency Transaction Reporting

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In order for each casino and card club to be fully compliant with Title 31, each employee should be aware of what compliance requirements are which is why an Anti-Money Laundering (AML) program is needed for each casino and card club. To be clear, CTR and SAR procedures, as well as MTL procedures, are included within the ATL program. CTR and SAR – Casino Telling the Government. Two primary reporting methods of the casino telling the government are the filing of a CURRENCY TRANSACTION REPORT (CTR) and a SUSPICIOUS ACTIVITY REFERRAL (SAR). CURRENCY TRANSACTION REPORT (CTR) Submitted by financial institutions for a transaction involving more than $10,000 in cash. (This includes “buy-ins” for table games.) The financial When filing the FinCEN CTR for a reportable transaction(s), the filing institution should complete a Part III for each location where the reportable transactions took place. The FinCEN CTR allows for up to 999 Part IIIs (Financial Institution Where Transaction(s) Takes Place) to be entered on a single filing. If the transactions take place at the branch level, the information regarding the Additionally, instructions are embedded within the discrete filing version of the FinCEN CTR and are revealed when scrolling over the relevant fields with your computer “mouse.” ADDITIONAL INFORMATION : BSA E-Filing provides a faster, more convenient, more secure, and more cost-effective method for submitting BSA forms. Learn more about BSA E-Filing here. News File FBAR Now. Filing the FBAR as an Individual? Access and Submit the FinCEN Report 114 FBAR for Individuals . Login. Existing Filer? Login to file BSA forms on behalf of your institution (or client) Support Center. Have a question or The FinCEN CTR should not be used to report receipts of currency in excess of $10,000 by any non-gaming businesses of a casino (e.g., a hotel). Instead, such transactions should be reported on Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. Casinos, gambling casinos, or card clubs with gross annual gaming revenues that are less than $1 million are not financial A casino or card club must aggregate customer currency transactions that occur on the floor or the cage, 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 ANALYSIS OF FILING TRENDS 7 QUALITY OF CTRC REPORTING 11 CONCLUSIONS 12 APPENDIX A 13 Guidance, Rules and Recent Releases Regarding the Casino Industry APPENDIX B 14 Law Enforcement Cases Relating to the Casino Industry Financial Crimes Enforcement Network Casino Industry Purpose As part of its efforts to provide efficient and effective administration of the Bank Secrecy Act (“BSA”)1 the E. A CTR must be electronically filed within 15 calendar days following the day the reportable transaction occurs (31 CFR 1010.306(a)(1)). The casino must retain copies of all filed Currency Transaction Report (CTR’s) for five years from the date of the report. For additional records to be made and retained by casinos, refer to 31 CFR 1010 Part III Casino Reporting Transactions *38 Address where transaction occurred (See instructions) *39 City *35 Casino’s trade name *41 ZIP code *37 Employer Identification Number (EIN) *40 State *31 CASH IN: (in U.S. dollar equivalent) 34 Foreign currency used: *32 CASH OUT: (in U.S. dollar equivalent) Cat. No. 37041B (03-11) *36 Casino’s legal name For Paperwork Reduction Act Notice, see

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