Save the Whales! Casinos to vet sources of funds?

Casinos will soon have to vet high-roller sources of funds.

Days of whales showing up with a suitcase full of cash may be over. I can't see them having to do more than see where the funds were wired from, just trying to stop cash.

I could be mistaken, but I was (and still am) under the impression that casinos already are subject to the same compliance as other financial institutions (banks, etc.).

Next up: Casinos will be required to ask patrons if they can really afford to lose "that amount of money."

I don't think it is any business of the casino where my money, or anyone elses, comes from. I can see them being required to fill out paperwork on cash amounts over a given threshold ($10,000?) the same way a bank would, but other than that it's none of their business.

Quote: rob45

I could be mistaken, but I was (and still am) under the impression that casinos already are subject to the same compliance as other financial institutions (banks, etc.).

From what I gather they currently need to just report it if it is suspicious, this will raise it. Think from passive to active checking on source of funds, as I read it anyways.

What are the requirements for banks in this regard? I recently made a large cash deposit at a bank and asked if they needed to know where it came from (I had W2Gs with me) and they were not interested.

Does this kick in at a certain threshold? This was well above the CTR threshold but not into the millions or anything crazy like that.

Quote: AZDuffman

From what I gather they currently need to just report it if it is suspicious, this will raise it. Think from passive to active checking on source of funds, as I read it anyways.

Regardless of amount, any activity considered suspicious must be reported by casino personnel. The whole point of the suspicious activity reporting (which has been in effect for quite a while now) is to counter those who have found ways to circumvent requirements.

I believe all reports go to the treasury department, and they decide whether to investigate or not.

I cannot imagine regulations being more stringent than what is currently (supposed to be) enforced.
Perhaps the treasury wants the casinos to do the investigations for them?

Quote: rob45

Regardless of amount, any activity considered suspicious must be reported by casino personnel. The whole point of the suspicious activity reporting (which has been in effect for quite a while now) is to counter those who have found ways to circumvent requirements.

But, what constitute suspicious?

If you fly in a high roller 2-3 times a year, and they show up with a million or two in cash each time, is that suspicious?

Quote: AxiomOfChoice

But, what constitute suspicious?

If you fly in a high roller 2-3 times a year, and they show up with a million or two in cash each time, is that suspicious?

Yes, that can be considered suspicious, but such an individual has already exceeded the CTR requirements. Why would suspicious activity need to be reported if the matter is already subject to investigation under the CTR?

What about the lady who closes her restaurant every night, then goes straight to the casino with $2K in twenty-dollar bills?
She obviously does not have enough to warrant CTR, but can that be considered suspicious? Yes. Is the casino supposed to fill out a report on her? Yes.

What about the individual who tries to buy in with a hundred-dollar bill that's so old that only a collector would recognize it as legal tender? He just wants to buy in for that $500 that his grandpa left him the week before passing away. Is this suspicious activity?
According to our gov't, if none of the casino personnel recognize that particular currency as being legal tender, then the casino must file a suspicious activity report.

There are many more examples, but my point is that if the gov't would actually work efficiently, one could easily determine that there is no need for more stringency. Rulings to cover all the loopholes have been in place since 9-11 occurred; bureaucracies are not utilizing them properly.
In the case of individuals with large buy-ins, they already have the necessary information for any investigation. My conclusion is that it should not be the responsibility of the casino to do the work the gov't should already be doing.

Quote: rob45

Yes, that can be considered suspicious, but such an individual has already exceeded the CTR requirements. Why would suspicious activity need to be reported if the matter is already subject to investigation under the CTR?

What about the lady who closes her restaurant every night, then goes straight to the casino with $2K in twenty-dollar bills?
She obviously does not have enough to warrant CTR, but can that be considered suspicious? Yes. Is the casino supposed to fill out a report on her? Yes.

What about the individual who tries to buy in with a hundred-dollar bill that's so old that only a collector would recognize it as legal tender? He just wants to buy in for that $500 that his grandpa left him the week before passing away. Is this suspicious activity?
According to our gov't, if none of the casino personnel recognize that particular currency as being legal tender, then the casino must file a suspicious activity report.

There are many more examples, but my point is that if the gov't would actually work efficiently, one could easily determine that there is no need for more stringency. Rulings to cover all the loopholes have been in place since 9-11 occurred; bureaucracies are not utilizing them properly.
In the case of individuals with large buy-ins, they already have the necessary information for any investigation. My conclusion is that it should not be the responsibility of the casino to do the work the gov't should already be doing.

Its to my understanding casinos are supposed to be keeping track of transactions that add up to $3,000. A form is supposed to be filled out by the employee with a description of the person. I know this used to be the case. Anything over 10k they are supposed to get all of your information.

Quote: AxelWolf

Its to my understanding casinos are supposed to be keeping track of transactions that add up to $3,000. A form is supposed to be filled out by the employee with a description of the person. I know this used to be the case. Anything over 10k they are supposed to get all of your information.

I have not yet been able to determine if reporting of multiple transactions (that add up to $3,000) is an actual requirement or if it is performed voluntarily by the casino as a preparatory measure.
I do know that in addition to filling out description, they also attach a photo to the form; at least one casino did (pit personnel aren't always as discreet as they believe).

Yes, over $10k means it's time for a CTR, where they get all your information (name, DOB, address, SSN, pet's name, pet's SSN, etc.).

Since this is common knowledge, individuals have devised more clever methods to circumvent the CTR. (AP'ing the gov't? :) j/k )
So they (the bureaucrats) have taken more restrictive measures and came up with what is labeled as a Suspicious Activity Report (SAR).
This type of report is to be filed for any activity considered "suspicious"; the problem with this is that the definition of "suspicious" is subject to the individual filing the report and the recipient of the report (FinCEN).
This type of report became prevalent sometime after 9-11 when terrorist financing was coming to light .

They have the CTR for all (including aggregate) transactions exceeding $10k. This absolutely must be reported; I know this from personal experience (the experience was not good).
For those who do not reach the CTR threshold, there's the SAR.
What more do they need?

Understandable information here.
Additional understandable information here.
Straight to the source, but good luck wading through it.