iamthepush
iamthepush
Joined: May 26, 2010
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June 9th, 2010 at 8:31:36 PM permalink
Last May I stayed at the Wynn and would buy in at a BJ table for about 200-400 and leave when I either busted or doubled or tripled up. I would take my winnings (when I had winnings), cash out and watch the cavs magic game (lebron hit that 3 to win) any ways one time i went to a table, gave them my players card and the pitboss told me that I'd have to fill out a form (a money laundering form ) b/c I had already bought in for 5K (iirc). so i just told him to give me my card back so i wouldn't get rated. is this true?
Wizard
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Wizard
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June 10th, 2010 at 1:58:04 AM permalink
There is a firm rule that any single transaction of 10K necessitates a CTR (Cash Transaction Report). This will include your Social Security Number and you'll have to produce ID if you're not already on file. The rule is supposed to apply to total cash transactions of 10K or over in a single day. So the floorman at the Wynn wanted to note that you already exchanged 5K in cash that day. You have the right to decline the request for a name at under 10K. As always, somebody correct me if this is wrong. I think I answered this in an old 'Ask the Wizard' question once.

The big debate among players I know, mainly high-limit sports bettors, is whether a lot of CTR's increases your odds of being audited. I have anecdotal evidence only, and not much of it. What I do know suggest that you need to have a lot of them to raise a red flag. How many is "a lot"? I'm not sure. I will go on record as saying I think you're okay with about 20 per year or less. Some will vehemently disagree, putting that number anywhere from 0 to infinity.
It's not whether you win or lose; it's whether or not you had a good bet.
DJTeddyBear
DJTeddyBear
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June 10th, 2010 at 5:32:12 AM permalink
It seems to me that, once the pit boss identified your transaction as requiring the CTR, a CTR should have been filled out regardless of what you did with the player's card.

But if you really want to avoid the CTR, why bring and buy in with cash?

No CTR is required when using casino credit / markers. Or am I wrong?
I invented a few casino games. Info: http://www.DaveMillerGaming.com/ 覧覧覧覧覧覧覧覧覧覧覧覧覧覧覧覧覧覧 Superstitions are silly, childish, irrational rituals, born out of fear of the unknown. But how much does it cost to knock on wood? 😁
Doc
Doc
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June 10th, 2010 at 6:28:14 AM permalink
As a cheapskate, I never play in a manner that has any chance of involving a CTR.

However, it is my understanding that one may (1) make a deposit at the casino cashier using a check (cashier's check or whatever they will accept) or wire transfer, (2) make your in-casino deposits/withdrawals in the form of chips, at the cashier or at a table with assistance of a pit supervisor, and (3) withdraw your remaining balance from the cashier as a check or wire transfer. If one follows that procedure, there should be no CTR no matter what amount of funds you are dealing with. The CTR is specifically a way to track large currency transactions. The use of checks and wire transfers eliminates the currency transactions and provides all of the tracking that the government requires.

Casinos are definitely not the only place one might incur a CTR, if you like to transfer funds in untraceable currency.

If you want to gamble with money borrowed from the casino, that's another technique, but one not to my taste.

The original poster's practice of converting cash to chips, then chips to cash, then cash to chips again is much like one might do if trying to launder money. Or foolishly trying to pass counterfeit. Such practices attract attention and lead to use of the CTR, even if everything is legitimate.
iamthepush
iamthepush
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June 10th, 2010 at 6:30:45 AM permalink
Quote: DJTeddyBear

It seems to me that, once the pit boss identified your transaction as requiring the CTR, a CTR should have been filled out regardless of what you did with the player's card.




i think that buy in would have put me over, so either i just bought in without giving them my card or i went to another table and didn't give them my card
konceptum
konceptum
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June 10th, 2010 at 7:00:10 AM permalink
In the event that a person refuses to fill out a CTR, a CTR is filled out anyway. The casino, or whoever is doing the CTR, will fill out the CTR with as much information as they can provide. In the situation where you are a relatively high dollar gambler anyway, and you have a player's card, then they will already know your name, and will fill out the CTR with that name. They also note on the CTR that you refused and/or denied to fill out the CTR. NOT filling out the CTR will raise more red flags than filling one out. As long as your money was gained legitimately, and you have nothing to hide, there is nothing necessarily wrong with filling out a CTR. On the other hand, if you earn a lot of money "under the table" so to speak, then you might have a "valid" reason for not wanting to fill out a CTR. But, in that case, you should either, not deal in cash, not deal with a casino that knows who you are, or keep your buy-ins to small amounts.
konceptum
konceptum
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June 10th, 2010 at 7:32:08 AM permalink
I should point out that my information is based upon discussions I've had with casino pit bosses, casino cashier managers, and also my interpretation of the rules written at www.fincen.gov.

"Question: When a customer refuses to provide a Social Security Number for completing a CTRC, can a casino or card club write 'refused' in item 7 of the CTRC?

Answer: No. When a casino or card club has obtained actual knowledge of a reportable currency transaction, it must obtain the identification information needed to file a complete and accurate CTRC, and then verify the name and address 'before concluding the transaction.'"

If you are buying in for less than the $10k threshold, there is a concern that a person might be "structuring", which is basically the idea of doing things knowing there is a $10k threshold, and trying to get around it. I've been told by pit bosses that if a person refuses to fill out a CTRC, their business will be turned away. However, the CTRC is only required for those transactions that exceed the $10k. Thus, if your transaction was only for $5k, they would not turn you away. The reason for presenting you with the CTRC was probably more of a friendly nod to you to let you know that because you are at half the threshold, should you buy in again with another $5k, they would be required to fill out the CTRC. By having you fill it out at the time, then it saves them from having to slow you down later on.


"Question: May a casino share information with another casino concerning potential suspicious activity?

Answer: Yes, casinos may utilize Section 314(b) information sharing to work together to identify money laundering and terrorist financing."

I was told at one point that if you decide to go across the street and gamble, the casinos could call each other and let them know you were coming. Thus, if you had a players card at one casino, the others could also know your information. Honestly, I'm not sure how much of that I believe. It seems like a lot of work for the casinos to go through. But I guess it would suppose on how much pressure the government places on them to report these kinds of things.

"Question: What are the civil penalties for non-compliance with BSA recordkeeping and reporting requirements?

Answer: FinCEN may seek civil money penalties of $25,000 a day per violation of any anti-money laundering compliance program requirement. Also, FinCEN may seek: (i) injunctive relif from a court against future violations of the BSA; (ii) civil money penalties of up to $25,000 or more per reporting violation (not to exceed $100,000); and (iii) other appropriate relief. In addition, FinCEN may seek civil money penalties (up to the amount of transaction) for structuring, attempting to structure, or assisting in structuring transactions."

Thus, gamble enough to cover the civil penalties, and maybe you'll be ok?

It's important to remember that in addition to the CTR, there is an SAR (Suspicious Activity Report), which can be filed for any dollar amount. Things included as being suspicious are: large currency exchanges; minimal gaming with large transactions; unusual use of negotiable instruments (checks); unusual use of counter checks or markers; as well as anything the casino my find suspicious.

So, again, not filling out a CTR may be considered suspicious and they may file an SAR on you. Then again, depending on how good of a customer you are, they might not.

This was from the answer to another question, but still applicable:

"Therefore, when a casino or card club cannot obtain identification information on reportable multiple transactions because a customer is no longer available, it must check its internal records or systems, including federal forms and records, which contain verified customer information. These records may include credit, deposit, or check cashing account records, or a previously filed CTRC form, IRS Form W-2G, or any other tax or other form containing such customer information."

In other words, they're going to send in whatever they may have on you. But again, I believe the standard policy if they don't know who you are, and you are trying to do something exceeding the $10k threshold, is to simply not do business with you.
konceptum
konceptum
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June 10th, 2010 at 9:50:44 AM permalink
Just talked to my girlfriend who worked in the banking industry. While some of the processes may be different than casinos, the basic laws are the same.

In the case where they already have your information (such as an established customer of the casino), they do not even have to inform you they are filling out a CTR. There is no signature required by the customer. The reason they let you know is out of courtesy, and also as a general check to make sure their information is up to date. Should you refuse to review the CTR, or display any sort of disapproval of the CTR, a bank would then write up an SAR. Not sure if a casino would do so as well.

In the case where you don't already have an existing relationship, the casino should ask for the CTR to be filled out, and if you don't give the information, they should refuse the transaction. Again, displaying concerns about filling out the CTR would result in an SAR. The banks/casinos are asked to perform their "due diligence" in obtaining the information, which means, theoretically, you could lie about your SSN on the form, and maybe other information. If an investigation into the transaction is done because of the fradulent information and/or SSN, then security tapes and other measures are taken as appropriate. This would, of course, be much worse than simply filling out the CTR. She said that banks have many BSA specialists whose sole jobs are to insure that the institution complies with the regulations. She says it's very likely that casinos also have BSA specialists.
Robmorrow
Robmorrow
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June 10th, 2010 at 10:33:18 AM permalink
BSA stands for?
iamthepush
iamthepush
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June 10th, 2010 at 11:04:10 AM permalink
Quote: Robmorrow

BSA stands for?



Bullshit attendant?

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