Frequently Asked Questions: Casino Recordkeeping, Reporting, and Compliance Program Requirements

Section A: 31 C.F.R. § 103.11 Casino and Card Club Definitions²

• Question 1: What gaming institutions are subject to the BSA casino regulatory requirements?
• Question 2: Is a tribal gaming establishment that offers only bingo and related games considered a casino for purposes of the BSA?
• Question 3: Is a "racino" considered a gaming institution subject to the BSA?
• Question 4: Would a race book or sports pool operator that has a "nonrestricted" Nevada gaming license be considered a casino for purposes of the BSA?
• Question 5: Is an establishment that offers only off-track betting on horse races considered a casino for purposes of the BSA?
• Question 6: Are "greyhound racing clubs" that offer table games considered gaming institutions for purposes of the BSA?
• Question 7: Are horse racetracks that offer pari-mutuel or other forms of wagering only on races held at the track considered casinos for purposes of the BSA?

Section B: 31 C.F.R. § 103.22 Currency Transaction Reporting Requirements¹⁸

• Question 8: Is a casino required to provide identification information on customers who have conducted reportable multiple currency transactions that were summarized through "after the fact aggregation?"
• Question 9: Is a casino required to use customer currency transaction information contained in the casino's slot monitoring system for purposes of BSA currency transaction reporting?
• Question 10: Is a cash wager/bet that is ultimately lost at a table game considered a transaction in currency for purposes of BSA currency transaction reporting?
• Question 11: Is a card club required to maintain and retain records of all currency transactions by customers pertaining to backline betting for purposes of currency transaction reporting?
• Question 12: Is a casino required to file FinCEN Form 103 (CTRC) on slot jackpot wins in excess of $10,000 in currency?
• Question 13: In the instructions to FinCEN Form 103, what does the word "periodically" mean when updating customer identification information for casino customers granted accounts for credit, deposit, or check cashing, or for whom a CTRC containing verified identity has been filed?

Section C: 31 C.F.R. § 103.21 Suspicious Transaction Reporting Requirements

• Question 14: How comprehensive must a casino's procedures be for detecting suspicious activity?
• Question 15: How can a casino complete suspicious activity reporting ("SAR") for "unknown" subjects?
• Question 16: Must a casino identify suspicious customer chip redemptions at a cage for reporting on FinCEN Form 102 (SARC)?
• Question 17: What type of information has law enforcement found to have particular value on FinCEN Form 102 (SARC)?
• Question 18: Should a casino or card club document the basis for its determination that a transaction is not suspicious?

Section D: 31 C.F.R. § 103.36 Casino Recordkeeping Requirements

• Question 19: What specific recordkeeping requirements apply to a casino?
• Question 20: What computer records must a casino retain?

Section E: 31 C.F.R. § 103.64(a) Compliance Program Requirements⁶⁷

• Question 21: How comprehensive must an internal and/or external testing program be to assure and monitor compliance with the BSA?
• Question 22: What type of compliance training program should be developed and what types of documentation should be maintained by a casino or card club to ensure that it has an adequate, accurate, and complete program?
• Question 23: What does the requirement mean that casinos that have automated data processing systems must use their automated programs to aid in assuring compliance?