Regulatory Alerts2009-07-01 | FinCEN Advisory – FIN-2009-A003Added
Structuring by Casino Patrons and Personnel (FinCEN Advisory – FIN-2009-A003)
Casinos and card clubs are required to implement compliance programs reasonably designed to deter, detect, and report structuring by patrons and personnel to evade Bank Secrecy Act reporting and recordkeeping requirements. If structured transactions involve or aggregate to at least $5,000 in funds or other assets, the entity must file a Suspicious Activity Report with full disclosure of subjects and relationships. FinCEN may impose civil money penalties of up to $25,000 per day for failure to maintain an adequate anti-money laundering program, up to the greater of the transaction amount or $25,000 for reporting violations, and up to the amount of coins and currency involved in structuring.
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