July 2005

Introduction

Distinguished colleagues, members of delegations, ladies and gentlemen, it is an honor and pleasure for me to welcome you to the 13th Plenary Session of the Egmont Group of Financial Intelligence Units. On behalf of my agency, the Financial Crimes Enforcement Network, I wish to express my deep appreciation to each of my colleagues for traveling to the City of Washington for this Plenary Session where we are also celebrating the 10th Anniversary of the Egmont Group. We hope and trust you have found your stay in the United States enjoyable.

Dear [ ]:
Thank you for your letter requesting our views concerning the extent to which financial institutions must establish programs to review currency transactions to detect and report “structuring” when the conduct does not require the filing of a currency transaction report. You also request guidance regarding the extent and parameters under which multiple day monitoring for potentially suspicious activity should be positively initiated.

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, as defined in our regulations, are not required to comply with rules specific to money services businesses.1 Instead, casinos and card clubs must comply with Bank Secrecy Act requirements designed specifically for these industries.2 I address below additional issues potentially implicated by your question.