Regulatory Alerts2005-02-07
Added
FinCEN Ruling 2005-1: Currency Transaction Reporting Aggregation by Casinos at Slot Machines
FinCEN determined that 31 C.F.R. § 103.22(c)(3) does not require casinos to aggregate currency transactions at slot machines if no officer, director, or employee has knowledge of the transactions by patron or identification card. This determination applies to casinos where employees do not perform complex data queries to obtain currency insertion information and do not observe such transactions. FinCEN noted that other Bank Secrecy Act provisions, such as anti-money laundering programs and suspicious transaction reporting, may still require casinos to obtain such knowledge. The ruling reserves the right to take action if the representations regarding the lack of employee knowledge prove inaccurate.
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