Regulatory Alerts2002-11-01
Added
FinCEN Guidance on CTR Exemption Eligibility for Tribally Owned and Operated Casinos
Depository institutions may exempt transactions conducted by a tribe or its department or agency from Currency Transaction Report requirements if the tribal casino is wholly-owned and operated by the tribe. Transactions are ineligible for exemption if carried out by an agent for a non-exempt beneficial owner, or if the casino is operated by a non-tribal management company or an independently-owned corporation where the tribe is merely a shareholder. When operational responsibilities are shared, institutions must determine eligibility based on the degree of tribal oversight, considering factors such as management contracts, management composition, presence of tribal officials, and tribal input on regulatory compliance.
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