pacomartin
pacomartin
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January 20th, 2010 at 3:56:47 PM permalink
I have a hypothetical question. Suppose you had a $100,000 in cash that you wish to launder over the course of three days. Over the course of three days different people make $5000 purchases of chips (so under IRS limit of $10K). ALl the chips are passed to gorilla who loudly plays blackjack at different times during the day at $1K limit on low house edge bets. At the end of the three days the gorilla turns in all the chips he has left. Maybe he is up a few thousand, maybe down a few thousand. But over the course of the three days he had a lot of different pit bosses. They all remember him, but nobody remembers him winning or losing very much. Since other people purchased the chips, there are no records of him buying all of those chips.
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I assume that the casino must fill out some kind of form that says they are turning over all this cash to the individual. The gorilla says they are winnings and he expects to pay income taxes. But now he has a record of where the money came from.
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The scenario makes more sense if the company owns multiple casinos which accept each other's chips.
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What is the casino's legal responsibility here? If the man claims that he won $90K I would assume that the casino's legal responsibility is only to give him the proper IRS form. Are they also responsible to review their video tapes, comp notes, and interview the pit bosses to see if the man actually won $90K or did he just fiddle about with the money. Do they have a fiduciary duty to report their suspicions even if they can't prove anything?
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There was a case in DC where teenagers were buying fancy cars with bags full of cash. The car salesmen saw the bags of cash, but claimed that they had no responsibility. The full responsibility was born by the finance departments of the car dealerships for accepting that much cash without filling out IRS forms.
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Just to show you how ignorant I am,what if someone purchases chips for $9000 and it's a mix of $1, $5, $10, $20, $50 and $100 banknotes. It hasn't broken the $10,000 limit, but your suspicions are probably valid. Are you legally obligated to report such a transaction?
FleaStiff
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January 20th, 2010 at 4:51:44 PM permalink
The casinos are sharp. They can reconcile all those cash transaction reports. And don't think those 5,000 transactions are somehow under the radar, they are not.

Loud obnoxious bettor flitting from table to table is going to get watched real close, particularly if he is making large bets irrespective of his doing it at different tables in different pits.

I understand that most money laundering these days is by blind-eye-bankers or by Offshore Money Laundering, Inc., which will weigh and automatically count and bundle your cash and physically transfer it offshore where it is laundered and returned as a business loan. OMLI representatives are found in several major cities. People who do business with OMLI never complain. Sometimes its because they are satisfied and sometimes its because they are dead, but either way, they never complain.
Croupier
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January 20th, 2010 at 5:24:12 PM permalink
Money Laundering via casinos as pointed out is extremely difficult. If someone ends up with a large amount of money, and it didnt come from buying in in the pit, we make damn sure we find out whose money it is. It is also procedure to report any suspicious transactions to the police.
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pacomartin
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January 21st, 2010 at 5:52:14 AM permalink
Quote: Croupier

It is also procedure to report any suspicious transactions to the police.



This was the core of my question. Do casinos report suspicious behavior or not? In the case of the car salesmen in Washington DC, they felt under no obligation to not deal with obviously suspicious behavior, simply saying that finance wasn't their responsibility.
Croupier
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January 21st, 2010 at 9:13:00 AM permalink
I think it is written into legislation here that failure to report any suspicion of criminal activity is in violation of the terms of the license to operate a casino. In the UK definately, anywhere else - not sure.
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AZDuffman
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January 21st, 2010 at 9:26:42 AM permalink
DISCLAIMER: FOR ENTERTAINMENT PURPOSES ONLY! BANKS DO LOOK FOR SOME OF THIS STUFF.


Quote: pacomartin

I have a hypothetical question. Suppose you had a $100,000 in cash that you wish to launder over the course of three days. Over the course of three days different people make $5000 purchases of chips (so under IRS limit of $10K). ALl the chips are passed to gorilla who loudly plays blackjack at different times during the day at $1K limit on low house edge bets. At the end of the three days the gorilla turns in all the chips he has left. Maybe he is up a few thousand, maybe down a few thousand. But over the course of the three days he had a lot of different pit bosses. They all remember him, but nobody remembers him winning or losing very much. Since other people purchased the chips, there are no records of him buying all of those chips.



$100,000 would actually be fairly easy to launder one time. I'd need more than three days, but assuming you have a bank account or two:

1. Drop $8-9,000 in your 2-3 accounts at different banks on different days. You shoudl have OLD accounts and not new ones. Get a friend if need be to let you use theirs for a small fee.

2. Get 5-6 money orders for another $8-9,000 each and overpay on your credit cards by $6-7,000. Spread it out over a few cards. Call the issuer when you have a credit and ask for a check back. Blame your wife for giving you the wrong value you needed to send when you were out of town or somehting.

Notice we are already 2/3 there!

Now, go to the banks you put the money in and ask for "secured loans" to establish credit. Take those checks and put the money in the main bank. Now money is in the main bank and assuming no one made a report you are safe. Make a few payments on the secured loans as needed so you don't red-flag.

Now, as my disclaimer says, banks will look for this. I learned it in an anti-money laundering course (and it is also at wikapedia.) But the point is it is very simple to launder a small amount and without looking up "money laundering" in a dictionary. You just conceal the source by channeling it thru an intermediary. What is hard is when you are some druk kingpin with $100,000 per month, week, or even day coming in.

I still don't understand the need to put cash into a casino if you take cash out. Unless it is known serial nunmbers from a heist (unlikely) you are still stuck with foldable cash and not the money in a bank.
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DJTeddyBear
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January 21st, 2010 at 10:01:48 AM permalink
Quote: AZDuffman

I still don't understand the need to put cash into a casino if you take cash out. Unless it is known serial nunmbers from a heist (unlikely) you are still stuck with foldable cash and not the money in a bank.

Ditto. Except that you can go to the cage and request a check.

Deposit that check.

If there are any questions, say it was all low payoff wins - the kind that don't need W2G (is that the right form?).

If you're depositing a check from a casino, its possible.

Of course, if you're depositing one every week or so, someone is gonna question how come you're so 'lucky'.
I invented a few casino games. Info: http://www.DaveMillerGaming.com/ ————————————————————————————————————— Superstitions are silly, childish, irrational rituals, born out of fear of the unknown. But how much does it cost to knock on wood? 😁
Mosca
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January 21st, 2010 at 2:10:08 PM permalink
Quote: pacomartin


There was a case in DC where teenagers were buying fancy cars with bags full of cash. The car salesmen saw the bags of cash, but claimed that they had no responsibility. The full responsibility was born by the finance departments of the car dealerships for accepting that much cash without filling out IRS forms.



Huh. I actually do this for a living (F&I mgr).

A few things, a little off topic:

The person who actually accepts the money and hands the customer the receipt is personally responsible for filling out form 8300. Failure to do so results in a penalty of fine + prison. So, yeah, I'm the guy.

Form 8300 is for transactions OVER $10,000, but it makes sense to fill them out for anything near $10,000, because we are also obligated to file for suspicious transactions. So, if someone gives $9990 cash and a personal check for the rest, I usually fill out the form.

No structuring. It's OK to try and offer a low rate to a cash customer, but it is illegal to say, "You know, I gotta report that."

Multiple cashier's checks of less than $10,000 each but totaling more than $10,000 is cash. So are multiple payments on one transaction (excepting an installment contract), such as a deposit of $500 cash and then later a $9800 cashier's check, and "linked transactions", where, say, a customer buys a truck for $9800 cash and then a week later buys $500 worth of accessories, also with cash. So you have to remain vigilant.

We get audited on this stuff. Every few years an IRS agent will come in and ask to see a list of deals. It helps to have everything nice and squeaky; I make copies of all checks, so it is easy to show receipt of personal checks rather than cashier's checks. A deal either has an installment contract, copies of the checks, or form 8300 in it.

In 20 years, I've had 3 instances where the law has come in and asked for all documents relating to the deal. First one, the guy was embezzling, bought two cars with a bunch of cashiers checks from different banks. Second one, the girl worked the scale at a scrap yard and was shorting the scale. Third one was a drug dealer. In each instance, Form 8300 was key in catching the crooks. So it's not nonsense.
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AZDuffman
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January 22nd, 2010 at 9:16:04 AM permalink
Quote: Mosca

Quote: pacomartin


There was a case in DC where teenagers were buying fancy cars with bags full of cash. The car salesmen saw the bags of cash, but claimed that they had no responsibility. The full responsibility was born by the finance departments of the car dealerships for accepting that much cash without filling out IRS forms.



Huh. I actually do this for a living (F&I mgr).

A few things, a little off topic:

The person who actually accepts the money and hands the customer the receipt is personally responsible for filling out form 8300. Failure to do so results in a penalty of fine + prison. So, yeah, I'm the guy.

Form 8300 is for transactions OVER $10,000, but it makes sense to fill them out for anything near $10,000, because we are also obligated to file for suspicious transactions. So, if someone gives $9990 cash and a personal check for the rest, I usually fill out the form.

No structuring. It's OK to try and offer a low rate to a cash customer, but it is illegal to say, "You know, I gotta report that."

Multiple cashier's checks of less than $10,000 each but totaling more than $10,000 is cash. So are multiple payments on one transaction (excepting an installment contract), such as a deposit of $500 cash and then later a $9800 cashier's check, and "linked transactions", where, say, a customer buys a truck for $9800 cash and then a week later buys $500 worth of accessories, also with cash. So you have to remain vigilant.

We get audited on this stuff. Every few years an IRS agent will come in and ask to see a list of deals. It helps to have everything nice and squeaky; I make copies of all checks, so it is easy to show receipt of personal checks rather than cashier's checks. A deal either has an installment contract, copies of the checks, or form 8300 in it.

In 20 years, I've had 3 instances where the law has come in and asked for all documents relating to the deal. First one, the guy was embezzling, bought two cars with a bunch of cashiers checks from different banks. Second one, the girl worked the scale at a scrap yard and was shorting the scale. Third one was a drug dealer. In each instance, Form 8300 was key in catching the crooks. So it's not nonsense.



Just out of curisity, what constitutes a "cashier's check?" Is it any bank issued check or does it have to indicate "cashier's check" on it? I've been to banks and they offered a bank issued check for free but wanted say 10 for one that said "cashier's check."
All animals are equal, but some are more equal than others
Nareed
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January 22nd, 2010 at 9:25:57 AM permalink
Quote: AZDuffman

Just out of curisity, what constitutes a "cashier's check?" Is it any bank issued check or does it have to indicate "cashier's check" on it? I've been to banks and they offered a bank issued check for free but wanted say 10 for one that said "cashier's check."



It's a check issued by a bank, with a seal or some other mark that certifies the check has funds and the bank will pay it. It's like a certified check, but issued by the bank rather than by the account holder.

BTW, regarding money laundering at a acasino, one should ask "Do I want to commit an illegal act at a palce chock-full of surveillance cameras, and where obsessive attention to detail is given to all money?"
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AZDuffman
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January 22nd, 2010 at 11:28:15 AM permalink
Quote: Nareed

Quote: AZDuffman

Just out of curisity, what constitutes a "cashier's check?" Is it any bank issued check or does it have to indicate "cashier's check" on it? I've been to banks and they offered a bank issued check for free but wanted say 10 for one that said "cashier's check."



It's a check issued by a bank, with a seal or some other mark that certifies the check has funds and the bank will pay it. It's like a certified check, but issued by the bank rather than by the account holder.

BTW, regarding money laundering at a acasino, one should ask "Do I want to commit an illegal act at a palce chock-full of surveillance cameras, and where obsessive attention to detail is given to all money?"



So wait a minute--that would mean if I buy a car for cash or "bring my own" financing in the form of a check they will file a suspicious currency transaction form? (not a sight draft, a real check. Some of us still do that.)
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Mosca
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January 22nd, 2010 at 12:49:56 PM permalink
Quote: AZDuffman

So wait a minute--that would mean if I buy a car for cash or "bring my own" financing in the form of a check they will file a suspicious currency transaction form? (not a sight draft, a real check. Some of us still do that.)



No, not at all. If the check is loan proceeds (vehicle, home equity, personal loan, borrowed against savings, whatever), then that cashier's check would not be considered cash. A personal check is not considered cash. A cashier's check over $10,000 is not considered cash. Just cashier's checks (or money orders, or traveler's checks) of less than $10,000 are considered cash. So if you bring 1 check of $32,000, whether personal, or cashier, or loan proceeds, that is not cash. But 4 cashier's checks of $8000 each; that is considered cash.

From the definition:

Quote:

CASH. The term "cash" means the following:

*U.S. and foreign coin and currency received in any transaction.
* A cashier's check, money order, bank draft, or traveler's check having a face amount of $10,000 or less that is received in a designated reporting transaction (defined below), or that is received in any transaction in which the recipient knows that the instrument is being used in an attempt to avoid the reporting of the transaction under either section 6050I or 31 U.S.C. 5331.

Note. Cash does not include a check drawn on the payer's own account, such as a personal check, regardless of the amount.
....

Exceptions. A cashier's check, money order, bank draft, or traveler's check is not considered received in a designated reporting transaction if it constitutes the proceeds of a bank loan or if it is received as a payment on certain promissory notes, installment sales contracts, or down payment plans. See Publication 1544 for clarification.

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Dude
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January 22nd, 2010 at 8:56:17 PM permalink
Quote: DJTeddyBear

Quote: AZDuffman

I still don't understand the need to put cash into a casino if you take cash out. Unless it is known serial nunmbers from a heist (unlikely) you are still stuck with foldable cash and not the money in a bank.

Ditto. Except that you can go to the cage and request a check.

Deposit that check.

If there are any questions, say it was all low payoff wins - the kind that don't need W2G (is that the right form?).

If you're depositing a check from a casino, its possible.

Of course, if you're depositing one every week or so, someone is gonna question how come you're so 'lucky'.



In Las Vegas, you can only get a check for winnings. Strip casios will verify large winnings by checking your play for the trip. If you say that you won the money playing craps, for example, the cashier will call the craps pit boss. If you say you won it over 2-3 days, the cashier will have the supervisor call the Players Club or pit boss to review your tracked play.

(The definition of 'large winnings' varies by property, but it's easy to say that anything over $5k would be large in this context even at Wynn.)

What this means is you cannot get a check for the cash you put in. Laundering aside, if you buy in for $5k, play for 4 hours, end up ahead $500, then cash out, you can get a check for $500 but not for the original $5k -- that must be paid in cash.

Rules are different in NJ other states, but this is the case in NV.
FleaStiff
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March 19th, 2013 at 8:21:20 AM permalink
62 Million dollars laundered at Bellagio slot machines, Wynn has No Comment, Chinese Company's Liquidators seeking court action.

Naomi Rovnick Mar 18 2013

There are fresh allegations that some of the money that went missing from a Chinese company once listed on the Nasdaq may have been laundered through slot machines in Las Vegas casinos.

China Medical Technologies was listed on the Nasdaq from 2005 until February last year, and had the bluest of blue-chip advisers, underwriters, investors and creditors. It was wound up last July after missing interest payments. The company's liquidators now claim that $670 million of cash the company raised in its 2005 IPO and subsequent equity and bond sales cannot be located, upping their estimate from a previous $400 million.

In a December 31 filing, the Hong-Kong based liquidation firm alleged that hundreds of millions of dollars were "funneled to Wu [Xiaodong, its CEO] and his associates.

Bi put $62 million through slot machines at the Bellagio casino in Las Vegas between 2008 and 2012. Another source separately confirmed that the casino's records do show Bi's $62 million slot machine spend in that time period.
treetopbuddy
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March 19th, 2013 at 8:25:38 AM permalink
turn in your neighbor, way to go.
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onenickelmiracle
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March 19th, 2013 at 8:29:49 AM permalink
It is an obvious loophole so big you can drive a car through. If you had a diary, recorded 1 witness and 4 years later all the tapes will be long gone and nobody is going to remember anything. I think as long as you stick to the story, you might have a chance theoretically. Then if you consider your witness was dead by then(dead to begin with), it is even easier. It is probably easier to manufacture losses than to manufacture a win considering some of the procedures others have mentioned, at least on the tables. Using the machines might be easier, but more expensive.
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treetopbuddy
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March 19th, 2013 at 8:33:31 AM permalink
Quote: Croupier

Money Laundering via casinos as pointed out is extremely difficult. If someone ends up with a large amount of money, and it didnt come from buying in in the pit, we make damn sure we find out whose money it is. It is also procedure to report any suspicious transactions to the police.

Turn in your neighbor.. ..way to go. When did somebody else's money become your concern or casino's in this case?
Each day is better than the next
onenickelmiracle
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March 19th, 2013 at 8:58:02 AM permalink
Treetopbuddy, suspicious activity reporting is just part of their job. It certainly would be their problem if they never did what they were supposed to. It's just the way it is. I get it isn't fair when you consider the most powerful pull off the biggest scams without any fear of prosecution, but the lowest hanging fruit has to be picked.
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AZDuffman
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March 19th, 2013 at 9:00:22 AM permalink
Quote: FleaStiff

62 Million dollars laundered at Bellagio slot machines, Wynn has No Comment, Chinese Company's Liquidators seeking court action.

Naomi Rovnick Mar 18 2013

There are fresh allegations that some of the money that went missing from a Chinese company once listed on the Nasdaq may have been laundered through slot machines in Las Vegas casinos.

China Medical Technologies was listed on the Nasdaq from 2005 until February last year, and had the bluest of blue-chip advisers, underwriters, investors and creditors. It was wound up last July after missing interest payments. The company's liquidators now claim that $670 million of cash the company raised in its 2005 IPO and subsequent equity and bond sales cannot be located, upping their estimate from a previous $400 million.

In a December 31 filing, the Hong-Kong based liquidation firm alleged that hundreds of millions of dollars were "funneled to Wu [Xiaodong, its CEO] and his associates.

Bi put $62 million through slot machines at the Bellagio casino in Las Vegas between 2008 and 2012. Another source separately confirmed that the casino's records do show Bi's $62 million slot machine spend in that time period.



Wonder what kind of comp that ended up being worth.
All animals are equal, but some are more equal than others
DJTeddyBear
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March 19th, 2013 at 9:37:43 AM permalink
$640 million in CASH?

How do you A) have that much in cash on hand, and B) misplace it?

Even stretched out over many separate losses over many months, that's still a lot of cash....
I invented a few casino games. Info: http://www.DaveMillerGaming.com/ ————————————————————————————————————— Superstitions are silly, childish, irrational rituals, born out of fear of the unknown. But how much does it cost to knock on wood? 😁
DJTeddyBear
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March 19th, 2013 at 9:39:15 AM permalink
$640 million in CASH?

How do you A) have that much in cash on hand, and B) misplace it?

Even stretched out over many separate losses over many months, that's still a lot of cash....
I invented a few casino games. Info: http://www.DaveMillerGaming.com/ ————————————————————————————————————— Superstitions are silly, childish, irrational rituals, born out of fear of the unknown. But how much does it cost to knock on wood? 😁
1arrowheaddr
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March 19th, 2013 at 10:01:41 AM permalink
There was a case in my area where the money was laundered using USPS money orders, they eventually got caught though.
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