Regulatory Alerts2012-08-13
Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
FinCEN issued this guidance to interpret Bank Secrecy Act regulations for U.S. casinos and card clubs regarding recordkeeping, reporting, and compliance programs. The document clarifies that casinos must verify customer identities using official documents rather than ITINs, aggregate cash-in and cash-out transactions separately, and maintain records for five years. It further mandates risk-based internal controls to detect suspicious activities, including those involving slot machines, kiosk redemptions, and junket front money accounts.
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