RegAlert2007-11-14
Added · Updated
Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
The document interprets Bank Secrecy Act regulations for casinos and card clubs with gross annual gaming revenue exceeding $1 million, defining which entities constitute a casino under 31 C.F.R. Part 103. It clarifies that slot jackpot wins in excess of $10,000 are no longer reportable as currency transactions, while cash wagers at table games and backline betting in card clubs remain subject to reporting and record retention. Casinos must utilize internal records and automated systems to aggregate multiple currency transactions and verify customer identification, and are required to file Suspicious Activity Reports for transactions involving $5,000 or more when suspicious activity is known, suspected, or reasonably suspected.
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FIN-2007-G005
Issued Date
Guidance Subject
Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
Purpose
This document provides guidance interpreting the requirements of the Bank Secrecy Act ("BSA") regulations as they apply to the casino and card club industries in the United States.
Section A: 31 C.F.R. § 103.11 Casino and Card Club Definitions
Question 1: What gaming institutions are subject to the BSA casino regulatory requirements?
Answer 1
: A casino or a card club that is duly licensed or authorized to do business as such, and has gross annual gaming revenue in excess of $1 million, is a "financial institution" under the BSA. The definition applies to both land-based and riverboat operations licensed or authorized under the laws of a state, territory, or tribal jurisdiction, or under the Indian Gaming Regulatory Act.
Tribal gaming establishments that offer slot machines, video lottery terminals, or table games, and that have gross annual gaming revenue in excess of $1 million are covered by the definitions. Card clubs generally are subject to the same rules as casinos, unless a different treatment for card clubs is explicitly stated in 31 C.F.R. Part 103.
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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
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