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MDawg
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pwcrabbmelisabernts
July 12th, 2021 at 9:47:15 PM permalink
Wizard approved topic.

This topic has arisen in various discussions related to what it means when a casino issues a check to a player, however it is an important topic with reference to how casinos operate in general.

Casinos are very strict especially nowadays with their anti-money laundering provisions.

31 CFR § 1021.210 provides that casinos must implement anti-money laundering provisions. Allowing a check to be issued in exchange for cash, for example, is definitely not anti-money laundering!

In general, a check issued by a casino is only pursuant to a win.

This was from 1996
https://lasvegassun.com/news/1996/jun/09/laundering-laws-keep-casinos-in-check/


Nevada also bars certain transactions the Bank Secrecy Act allows. Specifically, it says casinos can't:

* Exchange more than $2,500 in cash for bills of a larger denomination.

* Issue a casino check in exchange for more than $2,500 in cash.

* Transfer more than $2,500 by wire or other means.


Again, the above were the rules in 1996.

And the rules are MUCH stricter today. Today they won't allow even one penny in cash to be converted to a casino check. For example, back in the very early 2000s people could still "money play" at the tables. Nowadays that is not allowed and only chips may be played at the tables. Just in general everything is much stricter now than it was, but even in 1996 there was no way anyone could convert any meaningful sum of cash into a check at a casino.

These are representative of the newer, stricter guidelines in place today:
https://www.americangaming.org/sites/default/files/Best%20Practice%202017.pdf

These are suggested rules for casinos, which have been adopted by nearly all Nevada casinos these days:



How does this play out in some real world examples?

1) Casino issued checks:

Bottom line:

It is IMPOSSIBLE for a person to receive a CHECK from a casino for cash put into action. That would be straight money laundering.

A check issued by the casino may be for only two things: (1) a return of a front money deposit made by cashier's check or bank wire, or (2) a verified win. END OF STORY. If the check is marked "Verified Win" or “Pit Winnings” it means verified win – such a notation is not placed on the check lightly, and is pursuant to the Casino’s Compliance Division. Some casinos do not bother to mark their check memos with anything at all, however, ANY check issued by a casino would be ONLY for (1) or (2) as described above.

At the cage when cashing out chips of any substantial value the cage must verify (A) that no markers (credit line instruments representing money borrowed) are owed, and (B) that the pit boss has verified the exact win. If the win is not verified the casino will not cash any chips at all, especially not high denomination ones, and will certainly not issue a check for any chips unless it verifies every penny of the win.

Yes you may “find” a 100 or even 500 chip, maybe even a 1000 chip at a high end casino, and cash it out for cash, without having to establish how you got it, but nowadays show up at the cage with thousands in chips and you are not getting anything back for those until you establish how you got them. And in any case, NO casino will issue a paper check for chips turned in at the cage unless it represents either a return of cashier’s check or wired in front money or a verified win.


2) Casino policies with reference to front money deposits.

I had a conversation with a WOV member about front money and credit and how it works as far as whether front money or credit is drawn against first when playing.

In general it is correct to say that if you have a credit line and win, and choose to deposit the winning chips at the cage, or deposit cash that you won somewhere else (another casino or say at sports book) that future draws at the tables will deduct against the front money first, and then against your line if you deplete all the front money with draws.

However what doesn’t seem to make sense, is the way the cage likes to hold on to all of your deposited chips or cash as one separate account, running a tally of what you have deposited, and a separate tally of any markers you have drawn, and then settle at the end of the trip. In other words, even though yes, in this scenario of depositing chips or cash at the cage any draws at the tables are technically drawn against front money first, still, the cage is keeping separate accounts and doesn’t like to give you your front money drawn markers back against a reduction of front money, until the end of the trip.

Let's say you have a $100K credit line and lose $50K in markers and then win $50K at another casino, come in and deposit $50K cash at the cage. Now you'd think, okay my line is clear. Now you have $50K in markers outstanding, $50K cash on deposit, and $100K available again.

However, in this instance, the casino doesn't like to give you your markers back yet, they prefer to just keep things running until the end of the trip, and settle everything then. Just the way they work.

This creates a somewhat odd situation where if you are playing at a table and lose, and want to pay off your markers with cash, the easiest way to do it, notwithstanding that it takes forever for the dealers to count it, is to pay cash at the tables. If you deposit the cash at the cage, the cage tends to want to hold both your cash – and your markers, until trip’s end.

To me, as a credit line player, getting into a situation where the casino has both your cash and your markers, doesn’t make sense to me, so in situations where I have lost at one casino, and won at the other, I either get a check from the winning casino, deposit it, get my own cashier’s check and then pay off the losing casino, or just get cash from the winning casino and give the cash at the tables of the losing casino and have them count it against my markers and give me back my markers then and there.


3) Casino acceptance of checks or bank wires

Another rule with reference to casinos is what form of checks, cashier’s checks or bank wires they will accept. Due to Compliance rules which essentially come down to anti-money laundering, casinos will accept only checks or cashier’s checks that are made out from the player himself. Banks will not issue cashier’s checks without putting down the name of the remitter, and for a casino to accept that cashier's check that remitter name must match the name of the player at the casino. Similarly incoming bank wires will be rejected unless they show as coming from the player.

In some circumstances, where the remitter of a cashier’s check or bank wire is an entity that the casino has verified as being 100% solely owned by the individual player, the casino will accept payment from that source as well.


In general these rules come down to that casinos are working hard to prevent cash from being converted to any other form of funds other than cash, and to prevent transfers of funds between individuals.

Cash in, cash out.

Check or wire in, check or wire out.

Checks only for winnings or return of check or bank wire front money.

Funds other than cash accepted only from the individual player or his solely owned entity.

And basically, no funds of any substantial amount (over $10,000 USD) accepted or credit issued until full identification of the player including, especially for U.S. players, tax identification numbers.


There is a whole related topic about when and where casinos will report cash transactions, but these reporting requirements are for CASH only – they do not apply to incoming or outgoing checks or bank wires.
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Marcusclark66
Marcusclark66
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July 12th, 2021 at 10:06:00 PM permalink
FinCEN is no joke to casinos and casinos pay attention with sharp pencils to whatever they say and request.

FYI, read and learn, stop the dumb questions!

https://tier1fin.com/alessa/blog/money-laundering-casinos-red-flag-indicators/

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Marcus Clark. Real Person; AKA MarcusClark66. *Professional Casino Security Expert. *Certified EMT *Certified Company Firearms Instructor. *Certified Gaming Regulations Interpreter for Corporate Applications. *Domestic UrbanTactical Combat Casualty Expert. *Tic-Tac-Toe Expert (Real Competitive Versions) & Mastering Chess. *Honorary & Official #1 Fan of the MDawg Adventures Club. *Mastering Cracking it. Bit-by-Bit, Piece-by-Piece Crediting Forum Members. *Certified Casino Property Entry & Exit Point Analyzer *Baccarat Winning Session Record: 12 out of 12 & 1 out of 1 Mini Session. Baccarat Losing Session Record: 2 Losing Sessions.
100xOdds
100xOdds
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July 13th, 2021 at 5:37:30 AM permalink
To me, a verified win means showing ID and getting a w2-G or 1099 form.

i play slots/vp and i've gotten a w2-G for any win of $1200 or more.
Most of the time i ask for a check since it's easier for me and takes almost the same amount of time for the slot attendant to return with cash or check.

i also play poker (east coast).
you get a 1099 for hitting a poker promo of $600 or more. (ie: high hand promo, bad beat jackpot)
the poker room pays you in chips.
i've never asked for a check but i've also never hit a big promo either.
(Wonder why it's a 1099 instead of w2-G?)

the bad beat jackpot is normally 5 figures, sometimes 6 figures.
if i hit that, i'm assuming since i provided ID for the 1099, i can get a check?
(i really dont want to be carrying 5figures in cash and be paranoid about people following me home)
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100xOdds
100xOdds
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July 13th, 2021 at 5:46:02 AM permalink
Now that im thinking about the topic, whats to stop someone from going into the high limit slots area and playing $500/spin to launder $?

payouts are 5figures easy and sometimes 6 figures.
do this twice a week, every week and you have a nice stack of casino checks.
Craps is paradise (Pair of dice). Lets hear it for the SpeedCount Mathletes :)
billryan
billryan
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July 13th, 2021 at 6:09:52 AM permalink
Why would anyone try to launder money thru a casino when there are literally thousands of small businesses that have far fewer eyes on them and don't have state regulators all over them.?
Zcore13
Zcore13
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Thanks for this post from:
100xOdds
July 13th, 2021 at 6:37:25 AM permalink
Quote: 100xOdds



i also play poker (east coast).
you get a 1099 for hitting a poker promo of $600 or more. (ie: high hand promo, bad beat jackpot)
the poker room pays you in chips.
i've never asked for a check but i've also never hit a big promo either.
(Wonder why it's a 1099 instead of w2-G?)



A W-2G is for when you make a wager and win a specific amount. Place a lucky ladies bet,, win $10,000. Place a slot wager, hit a jackpot.

A 1099 is when you win something without a specific bet. Play poker, win the bad beat jackpot. Get a royal flush, win $1,000. Get a ticket for a drawing, win a car.


ZCore13
I am an employee of a Casino. Former Table Games Director,, current Pit Supervisor. All the personal opinions I post are my own and do not represent the opinions of the Casino or Tribe that I work for.
AxelWolf
AxelWolf
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July 13th, 2021 at 8:59:22 AM permalink
Quote: 100xOdds

Now that im thinking about the topic, whats to stop someone from going into the high limit slots area and playing $500/spin to launder $?

payouts are 5figures easy and sometimes 6 figures.
do this twice a week, every week and you have a nice stack of casino checks.

A question as to where you got the money to pay $500 a spin might come up. If you are using a card there would be a record of your activity, if you are gaming enough at that level there's a chance they could file a SAR on you. Not using a card at that level might be a red flag. You are also giving up whatever the machines holds with a ton of variance.
♪♪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♪♪
darkoz
darkoz
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July 13th, 2021 at 9:21:16 AM permalink
Quote: AxelWolf

A question as to where you got the money to pay $500 a spin might come up. If you are using a card there would be a record of your activity, if you are gaming enough at that level there's a chance they could file a SAR on you. Not using a card at that level might be a red flag. You are also giving up whatever the machines holds with a ton of variance.



If you don't create a log the IRS will count each jackpot as your profit and not allow for losses, correct?

So you just say the first jackpot was your first spin ($500 is not a huge amount) and you got lucky. Then it financed your further gambling.

Of course the IRS can then say what about the spins you didn't win but if that's where they are going then they have to accept your logs or lack thereof and get less taxes as a result.

Funny, I don't see them doing that.

As for not using a player card it's an option they give even at that level and with winning Jackpots and having to show ID, I don't see why a red flag would go up. You obviously are not hiding. You just are a high roller who doesn't give a damn about comps. Actually saves them promo expenditures
For Whom the bus tolls; The bus tolls for thee
billryan
billryan
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July 13th, 2021 at 9:22:40 AM permalink
When NY race tracks and OTB switched over to self-service kiosks, drug dealers quickly took advantage of it.
They realized this was a way for them to cash in their small denomination bills by hiring smurfs for a few bucks an hour stuffing the money into the machines. The next part was ingenious. They recruited a couple of small-time horse trainers into their scheme.
The trainers would list a horse in a race later in the week. The smurfs would pump the money into the machines and before the race, the horse would scratch and the tickets would be refunded in nice clean big bills.
It seems like a lot of work but the days of walking into a bank and depositing duffle bags full of twenties are long gone.
AxelWolf
AxelWolf
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July 13th, 2021 at 9:33:30 AM permalink
Quote: billryan

Why would anyone try to launder money thru a casino when there are literally thousands of small businesses that have far fewer eyes on them and don't have state regulators all over them.?

Perhaps the setup involved, Business licenses, accounting, banking, risk of being audited and things not making sense.



I think a mid to high-level poker player persona could be a solution. I have only been asked for my information one time while buying chips, and never when cashing out chips.
People buy chips off each other right at the table all the time and it doesn't seem like anyone is keeping track of that.

I guess it all comes down to how much money and how often you need to launder and what kind of time you want to spend doing it.
♪♪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♪♪

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