![]() ![]() Using identification that appears to be altered or forgedĮach casino should have its own, risk-based, compliance program and compliance officerĪ casino’s size, location, dollar volume, types of games, type/nature of customers, and internal controls are some of the factors to consider when analyzing the possible risk of money laundering occurring at the casino.Section A: 31 C.F.R.Using the casino purely for its financial services.Supplying other patrons with cash to purchase chips.Purchasing chips and then, after minimal gambling, redeeming the chips for a check.Regularly conducting currency transactions that are just below $10,000.Ğxchanging several monetary instruments, such as traveler’s checks, for one casino check. ![]() Ğxchanging many small bills for large ones.involves use of the casino to facilitate criminal activity.Īctivities that are considered suspicious for a Casino are:.has no business or apparent lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the casino knows of no reasonable explanation for the transaction after examining the available facts or.is designed to evade the reporting or recordkeeping requirements of the BSA (structuring).involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity (money laundering).Reimbursements for customers’ travel and entertainment expenses by the casinoīSA requires that Casinos file a Casino SAR (SARC) for any transaction conducted or attempted by, at, or through a casino, and involving or aggregating at least $5,000 in funds or other assets, that the casino knows, suspects, or has reason to suspect:.Ĝashing of checks or other negotiable instruments.Payments by a casino to a customer based on receipts of funds through wire transfer for credit to a customer.Payments on bets, excluding slot and video lottery terminal jackpots.Ědvances on any form of credit, including markers and counter checks.Redemption of chips, tokens and plaques.Transactions in currency involving cash-out include: Ğxchanges of currency for currency, including foreign currency.Ĝurrency received by a casino for transmittal of funds through wire transfer on behalf of a customer.Payments on any form of credit, including markers and counter checks.Transactions in currency involving cash-in include: Procedures for using computers to aid in assuring compliance, if the casino has computerized systems. Procedures for using all available information to determine any transactions or patterns of transactions required to be reported as suspicious andħ. Procedures for using all available information to verify the identity of a person, when required the name, address and Social Security Number (SSN).Ħ. Internal controls (policies and procedures designed to assure compliance with the Bank Secrecy Act (BSA) Ĥ.Ě compliance officer, who is responsible for day-to-day compliance with the BSA and the casino’s AML program ĥ. ![]()
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