February 2005

Good Afternoon. It is great to be back in Miami. As some of you in the room may know, I have spent a good deal of time in this region this past month. In fact, my wife is beginning to get suspicious. Convincing her that I am working down here and not playing golf has not been easy.

Dear [ ]:
This letter responds to your letters, dated June 18, 2004 and December 7, 2004, to the Financial Crimes Enforcement Network (“FinCEN”). In your letters, you request, on behalf of [Casino] and [Casino] (each a “Casino”), an administrative ruling that interprets 31 C.F.R. § 103.22(c)(3), the provision governing whether a casino must aggregate transactions in currency. You raise questions relating to aggregation and the insertion of currency into slot machines through bill validators.