Hunterhill
Hunterhill
Joined: Aug 1, 2011
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August 24th, 2016 at 11:37:51 AM permalink
This has been discussed numerous times.If you're a serious table games Ap you most likely need to carry cash. It's a risk factor we have to deal with.
The cops and local and state government agencies are crooks.Many of them factor these asset forfeitures into their annual budgets.
Your money is guilty until you prove its innocence.
For more on this check out Radley Balko in the Washington post or The Aclu website or the Institute for justice.
The mountain is tall but grass grows on top of the mountain.
Ibeatyouraces
Ibeatyouraces
Joined: Jan 12, 2010
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August 24th, 2016 at 11:45:17 AM permalink
Quote: Hunterhill

...If you're a serious table games Ap you most likely need to carry cash...


And a chip inventory from various casinos.
DUHHIIIIIIIII HEARD THAT!
LuckyPhow
LuckyPhow
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August 24th, 2016 at 12:07:23 PM permalink
777,

>>...I think it is more likely that you take thing out of context. I know for certain that for banking electronic or physical transaction, amount larger than $10,000 must be reported to the fed

True, financial transactions equal to or greater than $10K must be reported, whether done by your bank or your casino. I agree.

But, deposits of cash in amounts under $10K can also result in funds being seized. The Federales call it "structuring." Structuring refers to people who want to move more than $10K, but do it in smaller amounts under $10K so as not to trigger the financial oversight you referenced. Where that occurs, federal government agencies may decide to seize the money of anyone they believe may be trying this technique to avoid legal reporting requirements.

But, not everyone who has regular cash transactions under $10K is doing so to dodge the law. People who collect antiques (have you seen the popular TV show?) or who buy classic cars. Associations and social service groups who help with things like disaster relief, for example. And, lotsa small businesses. It is not uncommon for folks to have good reasons to use cash frequently in amounts under $10K.

Right, but why would the government want to seize money from those folks? I dunno, but they apparently do. Here's a story from the (rather conservative) Daily Signal (14-Jun-2016) about such seizures by the IRS:

Headline: For Americans Who Had Cash Seized By Government, a Chance to Get It Back

In a victory for lawmakers working to make it harder for the government to take property from innocent Americans, the Internal Revenue Service plans to give people who have had money seized over the last six years the chance to petition to get their money back, The Daily Signal has learned.
<snip>
Additionally, a subset of civil forfeiture laws regulating cash transactions allows the government to seize money from those accused of structuring violations. From 2005 to 2012, the IRS seized more than $242.6 million under structuring laws in more than 2,500 cases, according to the Institute for Justice. Both civil forfeiture and structuring laws were intended to target drug traffickers, money launderers, and those financing terrorist activities. However, small business owners have emerged in recent years telling of how theyíve had money seized by the IRS after the agency alleged they were structuring cash withdrawals and deposits to intentionally skirt reporting requirements.

But, why not just audit the businesses? Cash that was deposited and cash that was withdrawn from a bank wasn't being hidden, right? Aren't audits how IRS monitors this stuff? Duh! Much easier to allege the crime and seize the money than to conduct an audit.

There's a lot more in the story. Here's the link (admin help, please, if req'd):
http://dailysignal.com/2016/06/14/breaking-for-americans-who-had-cash-seized-by-government-a-chance-to-get-it-back/

And the Institute for Justice, mentioned above, also has lots of info. Not sure it will change your mind, but others may wish to know there's nothing magic about $10,000.
DeMango
DeMango
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August 24th, 2016 at 12:55:24 PM permalink
Quote: Ibeatyouraces

And a chip inventory from various casinos.



Which begs the question of where to keep that? Seems a whole lot easier to carry Pumpkins and Chocolates then huge wads of cash.
When a rock is thrown into a pack of dogs, the one that yells the loudest is the one who got hit.
AxelWolf
AxelWolf
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August 24th, 2016 at 1:02:34 PM permalink
Quote: 777

Quote: LuckyPhow

777,

>>...$10,000 non-reporting limit is Federal law.

Apparently, you didn't get the memo. Here's text from page 25 of the 2016 Department of Justice Asset Forfeiture Policy Manual:

Cash--minimum amount must be at least $5,000, unless the person from whom the cash was seized either was, or is, being criminally prosecuted by state or federal authorities for criminal activities related to the property, in which case the amount must be at least $1,000.

OK, so the real limit is $5,000, right? Sez so right in the manual, plain as can be. But, wait! There's more, because U.S. Attorney Office (USAO) has a lotta wriggle room (because these are only "guidelines"):

These guidelines are intended to be sufficiently flexible to enable each USAO (or in administrative matters, the agent in charge of a field office) to establish and utilize local procedures that clearly define and assign local pre-seizure/restraint planning responsibilities.

Uh-huh. Right. Page 21. Local offices can make up their own rules. So, there may really be no rules.



I think it is more likely that you take thing out of context. I know for certain that for banking electronic or physical transaction, amount larger than $10,000 must be reported to the fed, and I think the same rule is apply to transporting physical currency.

It doesn't have to be over 10k the are required to also report suspicious transfers or activity.
♪♪Now you swear and kick and beg us That you're not a gamblin' man Then you find you're back in Vegas With a handle in your hand♪♪ Your black cards can make you money So you hide them when you're able In the land of casinos and money You must put them on the table♪♪ You go back Jack do it again roulette wheels turinin' 'round and 'round♪♪ You go back Jack do it again♪♪
RS
RS
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August 24th, 2016 at 2:02:44 PM permalink
They are required to file a CTR (cash transaction report) for withdrawals or deposits totaling (the net of each separate) an amount greater than $10k. If you buy in for $10k exactly, a CTR will not be filed. I've done it before. Filing a CTR for an amount of $10k or less is illegal. Same with mandating an ID from a patron by lying and saying "it's needed for federal regulations/law" when it is not actually needed (i.e.: no CTR).

They are also required to file a SAR (suspicious activity report) for anything they, the casino, may deem suspicious. An example is someone buying in for $3,000, making a few small wagers, then cashing out. Buying in or cashing out multiple times in an apparent attempt to stay below the $10k threshold can be considered suspicious as well. Structuring is buying in or cashing out more than once within a 24-hour period in an attempt to thwart federal law / Title 31 reporting regulations.

It is NOT the player's responsibility to make sure these reports are filed or anything of the sort. The casino needs your ID & SSN when filing a CTR but not a SAR. It is illegal for the casino to tell ANYONE (except the US Treasury, I believe....but that's who gets the SAR anyway) that a SAR has been filed.....even to the person who it is being filed for (i.e.: the "suspicious" person), the police, or anyone else. A SAR being filed doesn't necessarily mean anything suspicious actually happened or the casino is suspicious of you.....I suppose it's more of a formality, something they do because they have to. If the casino cannot identify the person by obtaining ID, the casino (i.e.: cashier) should be as descriptive as possible regarding the person, when filing a SAR.

Casinos are becoming more strict with this kind of stuff, under Title 31, for anti-money-laundering.....since gambling is pretty much the easiest way to launder money, casinos have been a prime target for those wishing to launder money.


Carrying money on the other hand, that is not involved in a transfer (i.e.: someone having $20k in their pocket) is NOT subject to anything under Title 31 or federal reporting requirements. There is nothing that needs to be filed, no paperwork, no fancy IRS this or US Treasury that. Does not need to be reported, as long as it remains within the USA. If you plan on taking that money ($10k+) into the USA or to be taken out of the USA, as far as I know, it does need to be reported (but I don't really know about any of that stuff, I don't have much interest or care for traveling internationally with money).


TL;DR: Nothing needs to be reported if you are traveling within the USA. All the reporting stuff only has to deal with banks/casinos, or foreign travel. You can legally drive from Maine to California to Washington to Florida with $10M in your trunk, and you don't need to report a thing. (Not that you necessarily should.)

If I've made an error, please let me know. I'd rather read a source / law, not someone's opinion.....everyone's got one of those.



Edit: Some stuff edited above.
Edit2: If you're an AP, you should really learn this kind of stuff.
mcallister3200
mcallister3200
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August 24th, 2016 at 2:14:19 PM permalink
Quote: DeMango

Which begs the question of where to keep that? Seems a whole lot easier to carry Pumpkins and Chocolates then huge wads of cash.



Easier to carry, sure. Try cashing a chocolate if you played unrated though.....
777
777
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August 24th, 2016 at 3:58:00 PM permalink
Quote: RS

They are required to file a CTR (cash transaction report) for withdrawals or deposits totaling (the net of each separate) an amount greater than $10k. If you buy in for $10k exactly, a CTR will not be filed. I've done it before. Filing a CTR for an amount of $10k or less is illegal. Same with mandating an ID from a patron by lying and saying "it's needed for federal regulations/law" when it is not actually needed (i.e.: no CTR).

...

Casinos are becoming more strict with this kind of stuff, under Title 31, for anti-money-laundering.....since gambling is pretty much the easiest way to launder money, casinos have been a prime target for those wishing to launder money.



In banking transaction, I can see the value of money-laundering where money can be distributed to multiple individuals, organizations, and other businesses domestically and internationally. But for a typical chip buy-in & cash-out in a casino environment, how does money is laundered ? If a drug dealer took $100,000 cash (assume non-counterfeit bills) to a casino, and after combination of many bets and chip transactions, he/she then left the casino with an amount either less than or greater than his/her original cash depending on his/her luck. I donít see how the money was laundered in the cash/chip exchange scenario?

With regarding to CTR, how would the casino handle an international customer or a non-US citizen but legal resident customer who does not have SSN? The customer has only either a driver license, or a passport. Would the customer be asked to leave the property or be banned from the property forever for simply failing to provide a SSN?
RS
RS
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August 24th, 2016 at 4:10:07 PM permalink
Quote: 777

In banking transaction, I can see the value of money-laundering where money can be distributed to multiple individuals, organizations, and other businesses domestically and internationally. But for a typical chip buy-in & cash-out in a casino environment, how does money is laundered ? If a drug dealer took $100,000 cash (assume non-counterfeit bills) to a casino, and after combination of many bets and chip transactions, he/she then left the casino with an amount either less than or greater than his/her original cash depending on his/her luck. I donít see how the money was laundered in the cash/chip exchange scenario?

With regarding to CTR, how would the casino handle an international customer or a non-US citizen but legal resident customer who does not have SSN? The customer has only either a driver license, or a passport. Would the customer be asked to leave the property or be banned from the property forever for simply failing to provide a SSN?



I don't know HOW all the stuff actually works. I understand the theory behind it -- file SARs and CTRs to combat money-laundering...but I don't know exactly how that combats money-laundering. (Something I'm not much interested in.) As far as how someone would launder money, I really don't know, but I'd imagine the person just says they won more than they did. Take $20k, turn it into $15k (a net loss of $5k) and report it as a $10k win, or something like that.

As far as CTR / SSN / foreigner goes, I really don't know how that works. I've probably read it before, just didn't take note of it (not applicable to me). They probably write down their ID card number or some other identification number (like on a passport?). Really, don't know. =\
777
777
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August 24th, 2016 at 4:25:16 PM permalink
Quote: RS

I don't know HOW all the stuff actually works. I understand the theory behind it -- file SARs and CTRs to combat money-laundering...but I don't know exactly how that combats money-laundering. (Something I'm not much interested in.) As far as how someone would launder money, I really don't know, but I'd imagine the person just says they won more than they did. Take $20k, turn it into $15k (a net loss of $5k) and report it as a $10k win, or something like that.

As far as CTR / SSN / foreigner goes, I really don't know how that works. I've probably read it before, just didn't take note of it (not applicable to me). They probably write down their ID card number or some other identification number (like on a passport?). Really, don't know. =\



It makes sense. A drug dealer can make his $100,000 "illegal" money to look like a, say $80,000 legal gambling income through false or truthful reporting.

With regarding to CTR again, if a U.S. citizen customer REFUSE to provide SSN for whatever reason, how would the casino handle this? Will he/she be banned from the property for life?

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