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Financial Crimes Enforcement Network


Issued: August 1, 2008
Subject: Recognizing Suspicious Activity - Red Flags for Casinos and Card Clubs

This guidance is intended to assist casinos and card clubs1 with the reporting of suspected money laundering, terrorist financing and related financial crimes. This guidance contains examples of circumstances or "red flags" - based on actual reports, the observations of examiners and the experience of law enforcement - that may indicate the presence of money laundering, terrorist financing, and related financial crimes.

Casinos that are subject to the federal Bank Secrecy Act ("BSA") have an obligation to implement anti-money laundering programs that include procedures for detecting and reporting suspicious transactions. Casinos are required to implement risk-based anti-money laundering programs that assist with the identification and reporting of suspicious transactions, including employee training and written procedures on recognizing and addressing indicia of suspicious activity and vulnerabilities that may arise in the provision of particular products and services.

Recognizing Suspicious Customer Activity

Casino employees who monitor customer gaming activity or conduct transactions with customers are in a unique position to recognize transactions and activities that appear to have no legitimate purpose, are not usual for a specific player or type of players, or are not consistent with transactions involving wagering. Many casinos routinely obtain a great deal of information about their customers through deposit, credit, check cashing, player rating and slot club accounts. These accounts generally require casinos to obtain basic identification information about the accountholders and to inquire into the kinds of wagering activities in which the customer is likely to engage.

Attempts to Evade BSA Reporting or Recordkeeping Requirements

Be alert to customers who try to keep their transactions just below the reporting or recordkeeping thresholds, such as:

Using a Cage Solely for Its Banking-Like Financial Services

Be alert to customer activity involving unusual banking-like transactions at the cage, such as:

Minimal Gaming Activities Without Reasonable Explanations

Be alert to customers conducting large transactions on the floor with little or no related gaming activity and without reasonable explanation, such as:

Unusual Transaction Characteristics or Activities

Be alert to transactions with any unusual characteristics, such as:

Criminal Activities

Be alert to a customer conducting illegal activity, such as:

* * * * *

Questions or comments regarding the contents of this Guidance should be addressed to the FinCEN Regulatory Helpline at 800-949-2732.

1 See 31 U.S.C. 5312(a)(2)(X) and 31 C.F.R. 103.11(n)(5)(i) and (n)(6)(i). In this guidance, the term "casino" is used to refer to casinos, card clubs and other gaming establishments that fall within the BSA and FinCEN's regulations, unless otherwise noted.