Administrative Ruling on Cash Wagers as Bets of Currency

The Financial Crimes Enforcement Network determines that a cash wager on table game play constitutes a "bet of currency" and a "cash in" transaction under 31 C.F.R. § 103.22, regardless of whether the customer wins or loses. This classification applies once the customer can no longer retrieve the bet, such as after the dealer has dealt the cards. Consequently, casinos must report these transactions via Currency Transaction Reports if they exceed $10,000 in a gaming day and must aggregate multiple transactions based on knowledge acquired by officers, directors, employees, or partners.

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Ruling
FIN-2006-R002
Issued: March 24, 2006
Subject: Administrative Ruling
A Cash Wager on Table Game Play Represents a “Bet of Currency” Dear [ ]:
I am writing in response to your letter of November 18, 2004 to the Financial Crimes Enforcement Network requesting, on behalf of the [Regulatory Office], an administrative ruling that interprets the Bank Secrecy Act requirement to report casino currency transactions in excess of $10,000 in a gaming day.1

Specifically, you have requested a determination as to whether and when a cash wager on table game play represents a “bet of currency” and thus a transaction in currency involving “cash in” pursuant to 31 C.F.R. § 103.22. Based on the representations made in your letter, and as explained more fully below, the cash wagers you describe would be bets of currency2 and therefore subject to currency transaction reporting and associated aggregation requirements.3

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Lineage: In force

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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works