Regulatory Alerts2003-12-15
Added
Suspicious Activity Reporting Guidance for Casinos
Casinos meeting Bank Secrecy Act definitions must file a Casino Suspicious Activity Report for any transaction involving or aggregating at least $5,000 that they know, suspect, or have reason to suspect involves illegal activity, structuring, lacks a lawful purpose, or facilitates criminal activity. Filings are required within 30 calendar days of initial detection, with an additional 30 days permitted if a suspect cannot be identified, resulting in a maximum deadline of 60 calendar days. The guidance mandates that casinos develop written Anti-Money Laundering programs and complete the narrative section of the report with specific details regarding the transaction, subjects, and reasons for suspicion, while retaining backup materials internally rather than attaching them to the form.