The U.S. Casino and Gaming Industry: AML/BSA Regulation

The definition of a casino as a financial institution includes any branch office. Even though each separate casino license defines a casino as a financial institution for BSA purposes, some casinos may have branch offices to accept payments for debit and credit accounts. Transactions at these branch offices specific to a casino licensee are Casino - §1010.100(t)(5)(i) A casino or gambling casino that: Is duly licensed or authorized to do business as such in the United States, whether under the laws of a State or of a Territory or Insular Possession of the United States, or under the Indian Gaming Regulatory Act or other Federal, State, or tribal law or arrangement affecting Indian lands (including, without limitation, a casino FinCEN Ruling 2005-5. Definition of Money Services Business (Casinos as Money Services Businesses) Issued Date. July 06, 2005. Dear [ ]: I write in response to your letter of June 6, 2005 to the Financial Crimes Enforcement Network, in which you request guidance on whether casinos must comply with rules under the Bank Secrecy Act specific to money services businesses. Casinos and card clubs But access to the database, while helpful, would be much more helpful if FinCEN aligned the definition of “legal entity customer” under the CDD Rule with the definition of “reporting company” under the CTA. As noted above, U.S. companies are exempt from the CTA’s reporting requirement if they have a physical presence in the United States, over 20 full-time employees and federal FinCEN cannot just "tell casinos what to do" or issue a definitive "yes-or-no/check-the-box" form because every casino – and its money laundering risk – is different. A casino's program must therefore be tailored to the risks it faces, which in turn are based on the types of financial services it offers, the profile of its patrons and the community in which it is located. REMINDER: As of April 1, 2013, financial institutions must use the new FinCEN reports, which are available only electronically through the BSA E-Filing System.FinCEN is no longer accepting legacy reports. For more information, click here. Chapter X List for Casinos/Card Clubs (Updated November 18, 2010); Chapter X Main Page FinCEN also noted that, even when AJC had the information needed to properly file suspicious activity reports about cash-related transactions, the casino frequently failed to file corresponding currency transaction reports, or failed to state that both types of reports related to the same transaction. FinCEN found that the casino's policy-related and procedural shortcomings and failure to Hawaiian Gardens Casino: On July 15, 2016, FinCEN imposed a $2.8 million civil penalty against the casino for allegedly repeatedly violating its BSA requirements. FinCEN attributed these failures to the club’s lack of a compliance culture, emphasizing that: (1) its leadership failed to meet as required by its charter; (2) its leadership failed to review and approve its risk assessment; and

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