Per local casino licensee are a unique lender to possess purposes of complying that have currency exchange reporting

Per local casino licensee are a unique lender to possess purposes of complying that have currency exchange reporting

Address 8: Zero. When a casino otherwise cards club has actually acquired actual expertise in a beneficial reportable currency exchange, it must get the personality recommendations (such customer label, permanent address, and you may Social Protection Number (“SSN”)) had a need to file a complete and perfect CTRC, after which make sure title and you will address “just before concluding your order.” Whether your owner’s county driver’s license does not include a social Safety Number and the consumer will not promote a newsprint Public Safeguards Matter credit issued of the Personal Defense Government, a gambling establishment otherwise credit club is also go into a vocally offered SSN to your good CTRC. Plus, FinCEN knows that a casino might have the customer complete an enthusiastic Irs Means W-9, Ask for Taxpayer Personality Number and you can Degree, 30 to get another person’s proper Taxpayer Personality Count 32 or, in the event the buyers possess a deposit or borrowing account towards the gambling establishment, brand new local casino often comment this new membership to get the SSN since the the latest SSN is required at the time that the account is actually opened. 33 In every cases, a gambling establishment otherwise a credit bar need document a good CTRC getting reportable purchases with all of the needed pinpointing advice it features obtained from a customers, regulators facts they maintains and you may/and other confirmed internal information. 34

Matter nine: Are two alone subscribed, but jointly-had riverboat casinos which can be working regarding the same dock and you can sharing specific advice systems, necessary to aggregate currency deals by exact same customer one took place at each other casinos?


Respond to nine: Zero. A couple of riverboat gambling enterprises which can be not as much as preferred control and you can well-known government, display specific advice systems, look after equivalent accounting and you may inner handle measures, otherwise use the exact same docking place, however, having independent licenses, aren’t expected below 29 C. § (b)(2) and you may (c)(3) to aggregate and you may declaration customers currency purchases one happened on both establishment. thirty five Still, for a couple of riverboat casinos having automated analysis control expertise that will be closely incorporated, automated software for conformity into BSA ought to provide towards the usage of such expertise to assist in to ensure compliance that have pinpointing transactions that seem as suspicious and therefore is presented between the two gambling enterprises by recognized users 36 (age.grams., so you’re able to evade the newest $10,000 reporting requisite by way of structuring). 37

Question 10: Try a casino needed to document a good CTRC towards the buyers jackpot victories of gambling games aside from slot jackpot or video clips lottery terminal wins?

Address ten: Sure

A gambling establishment must file a good CTRC with the buyers jackpot wins paid in currency regarding gambling games other than slot jackpot otherwise video lotto critical wins. 38 These are typically among other online game, bingo (traditional), 39 Caribbean stud poker, keno, otherwise allow it to trip web based poker. forty This type of transactions may need to feel aggregated together with other dollars aside deals.

Answer 11: Yes, casinos get make use of Area 314(b) 41 recommendations sharing to the office together to spot money laundering and you will violent resource. And, casinos is make use of Area 314(b) suggestions revealing having depository institutions and money services companies. Point 314(b) since implemented by 31 C. § , set a secure harbor away from accountability to own a loan company otherwise association of financial institutions one to voluntarily decides to share suggestions with most other financial institutions with regards to distinguishing and you will, where suitable, revealing currency laundering otherwise violent pastime (if necessary alerts, verification and you can advice safeguards is actually set). Area 314(b) it permits discussing information based on purchases that a loan company suspects can get involve the brand new continues of just one or maybe more given unlawful factors listed in 18 U.S.C. §§ 1956 and 1957, which include numerous fake or any other criminal activities. 42 The new secure harbor afforded from the Point 314(b) is available to financial institutions which might be necessary to apply an anti-currency laundering system, that has, instance, depository establishments regulated of the a federal practical regulator, 43 casinos, and money attributes companies. 44