Casino Anti Money Laundering and Compliance

Who's got $600 anyway when a Lehman Event is happening?
Enraged Evergrande Investors Go Full Pitchfork, Hold Management Hostage In Company Offices | ZeroHedge
https://www.zerohedge.com/markets/enraged-evergrande-investors-go-full-pitchfork-hold-management-hostage-company-offices

RT Zerohedge: About $5 Trillion Sits in Money Funds, Most Yielding About Zero: BBG
About $300 billion sits with Evergrande earnings about 10%. Only that money is now gone... all gone

Proposed U.S. rule would force reporting of all accounts of $600 or more - Town Square Delaware LIVE
https://townsquaredelaware.com/proposed-u-s-rule-would-force-reporting-of-all-accounts-of-600-or-more/
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The part about monitoring bank accounts appears on page 88 (the 94th page of the PDF document):

> This proposal would create a comprehensive financial account information reporting regime. Financial institutions would report data on financial accounts in an information return. The annual return will report gross inflows and outflows with a breakdown for physical cash, transactions with a foreign account, and transfers to and from another account with the same owner. This requirement would apply to all business and personal accounts from financial institutions, including bank, loan, and investment accounts, with the exception of accounts below a low de minimis gross flow threshold of $600 or fair market value of $600. ...

> Similar reporting requirements would apply to crypto asset exchanges and custodians. Separately, reporting requirements would apply in cases in which taxpayers buy crypto assets from one broker and then transfer the crypto assets to another broker, and businesses that receive crypto assets in transactions with a fair market value of more than $10,000 would have to report such transactions. ...

> The proposal would be effective for tax years beginning after December 31, 2022.
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Will Banks Have To Report All Transactions Over $600 to IRS Under Biden Plan? | Snopes.com
https://www.snopes.com/fact-check/biden-banks-600-dollar-irs/

That would be overkill Big Brother oversight of bank accounts!

Yellen, IRS Push Democrats to Require Banks to Report Taxpayers’ Annual Account Flows
House Democrats didn’t include a bank account reporting provision in their tax bill, declining for now to adopt a Biden administration proposal.

Quote: ChumpChange

Is that to help Wells Fargo discover their scam bank accounts?
I wonder if casino cashier cages have to report $600 annually per player? Seems these stupid rules just won't go away.

link to original post

No. It is to control even the small aspects of our lives. For instance, mortgage payments, tuitions, renovations and, yes, even not-so-large buy-in's. But it appears that the only response is crickets, crickets. No surprise there.

Quote: AlanMendelson

Several years ago I made a whopper of a cash deposit at a Bank of America here in Vegas after a big win. I was asked for certain information for the CTR.

What troubled me is that the bank DID NOT ask where the cash came from. I wanted them to know that it came from CASINO WINNINGS because i knew i had losses to offset this win on my taxes.

The bank didnt want to hear anything about the casino. What they wanted was my BUSINESS INFO. And ONLY my business info was entered on the CTR.

This worried me, because I was afraid that this large cash deposit would raise red flags about my business and I was not going to include this large cash transaction as business income.

For that year I did report a loss on gambling and there were no repercussions. This happened more than five years ago.

So a question: have any of you actually had a CTR filed after depositing a large cash casino win and did your bank ask you about the casino and record the casino as the source of the cash??
link to original post

Quote: DRich

Quote: Mission146

The assumption that the casino gives one single, solitary, lonesome, isolated **** about where the money comes from is a curious one.

Sure, you probably couldn’t walk in and directly tell them it’s drug money, stolen money, whatever…but it’s not like they ask a whole hell of a lot of questions.

If it is over $10k they must report where the money came from. They are resposnible for asking you where it came from. If you say it came from your job, they will ask what you do. If you say lawyer for example they will ask what law firm and the address. They will also run your name through various databases to try and confirm it and make sure that you are not a Politically Exposed Person.
link to original post

Quote: unJon

I occasionally withdraw more than $10k from my bank. Without fail they ask me every time what my occupation is.
link to original post

I pulled $50,000. in cash on a recent win, and took the other $50K in check form, on a $100K+ winning session. I decided to deposit the cash at a different casino, not that I needed it, but just I figured - withdraw from one casino, a CTR must have been issued, deposit at another, the incoming CTR will cancel out any potential questions (if any questions are being asked). At least until I withdraw the cash again, but anyway, I figured, why not.

When I deposited the $50K cash the incoming recipient casino gave me a form to fill out that had some choices as to the source of the cash. I asked them why they wanted this.

"You've never asked for anything like this from me before."

The answer was that I had not deposited large sums of cash with them before - and this is true, generally I just withdraw cash or checks as winnings I don't deposit anything. I am a credit line player.

I didn't read through the form closely because the one option "Winnings from another casino" stood out, so I just checked it and filled in the blank for the name of the casino where I won the $100K+. I even showed the cashier a photo on my phone of the winning check for the other half and said, "See, here is the other half I won, I won even more than $50K there," but cage didn't seem to care.

"That's fine, just fill out the form, that's all we need."

Also the form included some lines for my occupation. I told the cage that they already had all that, they agreed, so I didn't have to fill out that portion. Nor did I have to fill out all the info about my identity, just filled in my name, as they have all that too.

But bottom line being that yes, if you try to deposit a bunch of cash apparently even a known player may be asked to identify its source.

Quote: MDawg

But bottom being that yes, if you try to deposit a bunch of cash apparently even a known player may be asked to identify its source.
link to original post

Yes, when I trained on CTR handling at casinos I always told them to ask for the source. A known player just doesn't need to give all of the personal information again.

I was in a cash-out line at closing time and several people had loads of big money chips in their hands. The cashier was asking for a Player's Card or an ID if the cash-out amount was over a certain amount. What that amount is, I don't know. But $3700 sure made one foreign person with no Player's Card have to show a DL. $100, they don't ask. So that limit could be anywhere between $100-$3700. For sure they enter your cash-out in the computer for a daily CTR. I'd expect the limit to be $2500 or $3K, but people were so flush with cash, maybe the limit is lower.

Quote: ChumpChange

I was in a cash-out line at closing time and several people had loads of big money chips in their hands. The cashier was asking for a Player's Card or an ID if the cash-out amount was over a certain amount. What that amount is, I don't know. But $3700 sure made one foreign person with no Player's Card have to show a DL. $100, they don't ask. So that limit could be anywhere between $100-$3700. For sure they enter your cash-out in the computer for a daily CTR. I'd expect the limit to be $2500 or $3K, but people were so flush with cash, maybe the limit is lower.
link to original post

Just because you saw him at that time with $3,700, doesn't mean that's all he cashed in all day. If he had cashed in any significant amounts earlier, they could have been keeping track by description. That $3,700 could have put him over $10,000.


ZCore13

A CTR is issued for 10K cash withdrawn or deposited within a 24 hour period.

Multiple deposits just under the limit that might be construed as structuring could result in the issuance of a SAR.

Quote: Zcore13

Quote: ChumpChange

I was in a cash-out line at closing time and several people had loads of big money chips in their hands. The cashier was asking for a Player's Card or an ID if the cash-out amount was over a certain amount. What that amount is, I don't know. But $3700 sure made one foreign person with no Player's Card have to show a DL. $100, they don't ask. So that limit could be anywhere between $100-$3700. For sure they enter your cash-out in the computer for a daily CTR. I'd expect the limit to be $2500 or $3K, but people were so flush with cash, maybe the limit is lower.
link to original post

Just because you saw him at that time with $3,700, doesn't mean that's all he cashed in all day. If he had cashed in any significant amounts earlier, they could have been keeping track by description. That $3,700 could have put him over $10,000.


ZCore13
link to original post

It was a little old lady who acted like she'd never been in line at the cashiers cage before.

Quote: MDawg

Quote: AlanMendelson

Several years ago I made a whopper of a cash deposit at a Bank of America here in Vegas after a big win. I was asked for certain information for the CTR.

What troubled me is that the bank DID NOT ask where the cash came from. I wanted them to know that it came from CASINO WINNINGS because i knew i had losses to offset this win on my taxes.

The bank didnt want to hear anything about the casino. What they wanted was my BUSINESS INFO. And ONLY my business info was entered on the CTR.

This worried me, because I was afraid that this large cash deposit would raise red flags about my business and I was not going to include this large cash transaction as business income.

For that year I did report a loss on gambling and there were no repercussions. This happened more than five years ago.

So a question: have any of you actually had a CTR filed after depositing a large cash casino win and did your bank ask you about the casino and record the casino as the source of the cash??
link to original post

Quote: DRich

Quote: Mission146

The assumption that the casino gives one single, solitary, lonesome, isolated **** about where the money comes from is a curious one.

Sure, you probably couldn’t walk in and directly tell them it’s drug money, stolen money, whatever…but it’s not like they ask a whole hell of a lot of questions.

If it is over $10k they must report where the money came from. They are resposnible for asking you where it came from. If you say it came from your job, they will ask what you do. If you say lawyer for example they will ask what law firm and the address. They will also run your name through various databases to try and confirm it and make sure that you are not a Politically Exposed Person.
link to original post

Quote: unJon

I occasionally withdraw more than $10k from my bank. Without fail they ask me every time what my occupation is.
link to original post

I pulled $50,000. in cash on a recent win, and took the other $50K in check form, on a $100K+ winning session. I decided to deposit the cash at a different casino, not that I needed it, but just I figured - withdraw from one casino, a CTR must have been issued, deposit at another, the incoming CTR will cancel out any potential questions (if any questions are being asked). At least until I withdraw the cash again, but anyway, I figured, why not.

When I deposited the $50K cash the incoming recipient casino gave me a form to fill out that had some choices as to the source of the cash. I asked them why they wanted this.

"You've never asked for anything like this from me before."

The answer was that I had not deposited large sums of cash with them before - and this is true, generally I just withdraw cash or checks as winnings I don't deposit anything. I am a credit line player.

I didn't read through the form closely because the one option "Winnings from another casino" stood out, so I just checked it and filled in the blank for the name of the casino where I won the $100K+. I even showed the cashier a photo on my phone of the winning check for the other half and said, "See, here is the other half I won, I won even more than $50K there," but cage didn't seem to care.

"That's fine, just fill out the form, that's all we need."

Also the form included some lines for my occupation. I told the cage that they already had all that, they agreed, so I didn't have to fill out that portion. Nor did I have to fill out all the info about my identity, just filled in my name, as they have all that too.

But bottom line being that yes, if you try to deposit a bunch of cash apparently even a known player may be asked to identify its source.
link to original post

FYI, CTRs are automatically generated once you are established at any given casino property. Each time you engage in a $10k cash transaction it will be issued and sent in. No need for a patron to ever sign it, see it or even be told it is being generated. Depending on the casinos protocols, possibly every year or more, the patrons ID might be verified.

All sections are not necessary, especially for an established player.

As well, once established SARS/STRa are almost never generated. They are for those that refuse ID and are acting suspicious according to guidelines issued by the government, etc.

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.?
link to original post

I don't know what this is about... There is such an assumption. And to satisfy their needs (there are addicted people), or it is profitable...
I was at a table where a guy was betting mad stacks, including on bad bets on other players spots; he was losing a lot and didn’t mind. One of the other guys, I think he owned gas stations (also betting a lot) hit royal flush and the guy had a piece of it. I got the strong feeling that the guy betting on other people’s spots was a dealer. I can’t prove it, maybe he was hired by dealers to launder for them; but I figure there are lower house edge games than the way he was playing. He probably still lost a bundle after a massive win gave him some back.

I would think a logical launderer would either play simple, low house edge games like Baccarat. It’s possible they might choose craps, as you can get more money on the table with odds and that brings the house edge even lower. You might be able to play $500 pass line and $1500–5000 odds since 3–4–5x odds is common and some places do 10x odds. But, you have to fill out forms if you cash out or buy in for $10k+ in a day. Of course, you can save chips for the next day or have friends cash in chips.

Quote: ChumpChange

I was in a cash-out line at closing time and several people had loads of big money chips in their hands. The cashier was asking for a Player's Card or an ID if the cash-out amount was over a certain amount. What that amount is, I don't know. But $3700 sure made one foreign person with no Player's Card have to show a DL. $100, they don't ask. So that limit could be anywhere between $100-$3700. For sure they enter your cash-out in the computer for a daily CTR. I'd expect the limit to be $2500 or $3K, but people were so flush with cash, maybe the limit is lower.
link to original post

I trained our personnel to start asking for ID at $3000 and fill in the Multiple Transaction Log.

Quote: DRich

I trained our personnel to start asking for ID at $3000 and fill in the Multiple Transaction Log.
link to original post

DRich,

What do you tell your personnel to do if the customer wants to cash in $4K in chips but declines to show ID?

Dog Hand

Quote: DogHand

Quote: DRich

I trained our personnel to start asking for ID at $3000 and fill in the Multiple Transaction Log.
link to original post

DRich,

What do you tell your personnel to do if the customer wants to cash in $4K in chips but declines to show ID?

Dog Hand
link to original post

Allow them to cash out but write down a description of then in case they try to cash in more. If they get to $10k refuse to cash out anymore until they produce ID.

If I'm trying to win $15,000 on a Bubble Craps machine in one day and the machine doesn't register above $3,000 credits but instead spits out vouchers starting at a sub-$3,000 balance, and the vouchers have a one year expiration date, can I just bring back a couple dozen <$400 vouchers (won by playing the Don'ts, might be a higher amount if it includes the original bet) to cash-in on another day, or I could just use them like "take home chips" and use them for play on another day? My buy-in would likely be $1500.

I've heard talk at the Bubble Craps machine about antics going on at the real craps tables nearby. A couple stories: one guy put $400 on each of the hardways and won 2 in a row; another guy was winning big and was up $30K so they closed the table, he went to another table and they closed that one too.

Quote: ChumpChange

If I'm trying to win $15,000 on a Bubble Craps machine in one day and the machine doesn't register above $3,000 credits but instead spits out vouchers starting at a sub-$3,000 balance, and the vouchers have a one year expiration date, can I just bring back a couple dozen <$400 vouchers (won by playing the Don'ts, might be a higher amount if it includes the original bet) to cash-in on another day, or I could just use them like "take home chips" and use them for play on another day? My buy-in would likely be $1500.

I've heard talk at the Bubble Craps machine about antics going on at the real craps tables nearby. A couple stories: one guy put $400 on each of the hardways and won 2 in a row; another guy was winning big and was up $30K so they closed the table, he went to another table and they closed that one too.
link to original post

You can and I highly doubt there would be any issues, but that could be considered structuring.

Quote: MDawg

Quote: AlanMendelson

Several years ago I made a whopper of a cash deposit at a Bank of America here in Vegas after a big win. I was asked for certain information for the CTR.

What troubled me is that the bank DID NOT ask where the cash came from. I wanted them to know that it came from CASINO WINNINGS because i knew i had losses to offset this win on my taxes.

The bank didnt want to hear anything about the casino. What they wanted was my BUSINESS INFO. And ONLY my business info was entered on the CTR.

This worried me, because I was afraid that this large cash deposit would raise red flags about my business and I was not going to include this large cash transaction as business income.

For that year I did report a loss on gambling and there were no repercussions. This happened more than five years ago.

So a question: have any of you actually had a CTR filed after depositing a large cash casino win and did your bank ask you about the casino and record the casino as the source of the cash??
link to original post

Quote: DRich

Quote: Mission146

The assumption that the casino gives one single, solitary, lonesome, isolated **** about where the money comes from is a curious one.

Sure, you probably couldn’t walk in and directly tell them it’s drug money, stolen money, whatever…but it’s not like they ask a whole hell of a lot of questions.

If it is over $10k they must report where the money came from. They are resposnible for asking you where it came from. If you say it came from your job, they will ask what you do. If you say lawyer for example they will ask what law firm and the address. They will also run your name through various databases to try and confirm it and make sure that you are not a Politically Exposed Person.
link to original post

Quote: unJon

I occasionally withdraw more than $10k from my bank. Without fail they ask me every time what my occupation is.
link to original post

I pulled $50,000. in cash on a recent win, and took the other $50K in check form, on a $100K+ winning session. I decided to deposit the cash at a different casino, not that I needed it, but just I figured - withdraw from one casino, a CTR must have been issued, deposit at another, the incoming CTR will cancel out any potential questions (if any questions are being asked). At least until I withdraw the cash again, but anyway, I figured, why not.

When I deposited the $50K cash the incoming recipient casino gave me a form to fill out that had some choices as to the source of the cash. I asked them why they wanted this.

"You've never asked for anything like this from me before."

The answer was that I had not deposited large sums of cash with them before - and this is true, generally I just withdraw cash or checks as winnings I don't deposit anything. I am a credit line player.

I didn't read through the form closely because the one option "Winnings from another casino" stood out, so I just checked it and filled in the blank for the name of the casino where I won the $100K+. I even showed the cashier a photo on my phone of the winning check for the other half and said, "See, here is the other half I won, I won even more than $50K there," but cage didn't seem to care.

"That's fine, just fill out the form, that's all we need."

Also the form included some lines for my occupation. I told the cage that they already had all that, they agreed, so I didn't have to fill out that portion. Nor did I have to fill out all the info about my identity, just filled in my name, as they have all that too.

But bottom line being that yes, if you try to deposit a bunch of cash apparently even a known player may be asked to identify its source.
link to original post

I deposited $20K cash from recent winnings at the same casino as mentioned above, mostly just to see what would happen - this time, no questions and no form. Perhaps the trigger for questioning - at least for me - is more like around $50K?

Quote: MDawg

Quote: MDawg

Quote: AlanMendelson

Several years ago I made a whopper of a cash deposit at a Bank of America here in Vegas after a big win. I was asked for certain information for the CTR.

What troubled me is that the bank DID NOT ask where the cash came from. I wanted them to know that it came from CASINO WINNINGS because i knew i had losses to offset this win on my taxes.

The bank didnt want to hear anything about the casino. What they wanted was my BUSINESS INFO. And ONLY my business info was entered on the CTR.

This worried me, because I was afraid that this large cash deposit would raise red flags about my business and I was not going to include this large cash transaction as business income.

For that year I did report a loss on gambling and there were no repercussions. This happened more than five years ago.

So a question: have any of you actually had a CTR filed after depositing a large cash casino win and did your bank ask you about the casino and record the casino as the source of the cash??
link to original post

Quote: DRich

Quote: Mission146

The assumption that the casino gives one single, solitary, lonesome, isolated **** about where the money comes from is a curious one.

Sure, you probably couldn’t walk in and directly tell them it’s drug money, stolen money, whatever…but it’s not like they ask a whole hell of a lot of questions.

If it is over $10k they must report where the money came from. They are resposnible for asking you where it came from. If you say it came from your job, they will ask what you do. If you say lawyer for example they will ask what law firm and the address. They will also run your name through various databases to try and confirm it and make sure that you are not a Politically Exposed Person.
link to original post

Quote: unJon

I occasionally withdraw more than $10k from my bank. Without fail they ask me every time what my occupation is.
link to original post

I pulled $50,000. in cash on a recent win, and took the other $50K in check form, on a $100K+ winning session. I decided to deposit the cash at a different casino, not that I needed it, but just I figured - withdraw from one casino, a CTR must have been issued, deposit at another, the incoming CTR will cancel out any potential questions (if any questions are being asked). At least until I withdraw the cash again, but anyway, I figured, why not.

When I deposited the $50K cash the incoming recipient casino gave me a form to fill out that had some choices as to the source of the cash. I asked them why they wanted this.

"You've never asked for anything like this from me before."

The answer was that I had not deposited large sums of cash with them before - and this is true, generally I just withdraw cash or checks as winnings I don't deposit anything. I am a credit line player.

I didn't read through the form closely because the one option "Winnings from another casino" stood out, so I just checked it and filled in the blank for the name of the casino where I won the $100K+. I even showed the cashier a photo on my phone of the winning check for the other half and said, "See, here is the other half I won, I won even more than $50K there," but cage didn't seem to care.

"That's fine, just fill out the form, that's all we need."

Also the form included some lines for my occupation. I told the cage that they already had all that, they agreed, so I didn't have to fill out that portion. Nor did I have to fill out all the info about my identity, just filled in my name, as they have all that too.

But bottom line being that yes, if you try to deposit a bunch of cash apparently even a known player may be asked to identify its source.
link to original post

I deposited $20K cash from recent winnings at the same casino as mentioned above, mostly just to see what would happen - this time, no questions and no form. Perhaps the trigger for questioning - at least for me - is more like around $50K?
link to original post

If you are already a known customer they wouldn't ask you anything or give you anything. They are supposed to still file a CTR

I am a very well known customer, but as stated, when I deposited 50K cash recently - form to fill out anyway. When I deposited 20K, same casino, no form. I don't usually withdraw or deposit large sums of cash, generally I withdraw most winnings in checks - I have deviated a bit from "checks only" lately.

I assume that any casino where I have withdrawn or deposited more than $10K / 24 hours has filed a CTR, but as you and I know, that is something done behind the scenes not like they will tell me about it or hand me anything to memorialize it.

Quote: ChumpChange

I was in a cash-out line at closing time and several people had loads of big money chips in their hands. The cashier was asking for a Player's Card or an ID if the cash-out amount was over a certain amount. What that amount is, I don't know. But $3700 sure made one foreign person with no Player's Card have to show a DL. $100, they don't ask. So that limit could be anywhere between $100-$3700. For sure they enter your cash-out in the computer for a daily CTR. I'd expect the limit to be $2500 or $3K, but people were so flush with cash, maybe the limit is lower.
link to original post

A cage, on the vegas strip, asked for id. I cashed i think 2k. They knew that i was a card counter quickly in vegas. I really wasnt cautious enough.

I didnt follow counter surveilance protocol well. Avg profit per day was 250. With about 5 hours of play per day. Based after 1 thousand hours of play.

I would still be card counting. But the family business was losing 1k per day. Outsourced maintenance alone was 1k per day. Internal theft was somewhere between 500 to 1k per day. Partly, in raw meat theft, free food and cash. Also, i replaced mowing service for 10 acres. A renter is paying 58 cents per sq ft for 12,500 ft of climate controlled office space. After parents pass, Im evicting them. I loaned the business from my personal acct 600k to cover some of the losses. I recovered 3/4 back.

I have also heard about money laundering schemes using the gaming business. I think it's just hard to keep track of money when somebody win. In addition, in many countries such winnings are not taxed.

Had a situation, not exactly just now, but recently, where I won some, held on to the chips,
then had a loss, paid it off in cash,
kept playing, won,
(all this over a period of days)
and when it came time to get a winning check, the casino balked at how many five thousand dollars chips I had. Said that the computer showed me winning only x amount, which basically was the sum of all I had in chips minus the cash I paid off against the loss along the way.

Try as I might, couldn't convince the casino to issue me a check for all of my chips - only for the net win that the casino had down on their system for the trip.

And that's how strict they are these days, notwithstanding some cob webbed recollections of yesteryear and musings that checks are available without winning.

You can't use PhotoShop to redact serial numbers off currency. Other apps don't seem to care but PS does.

Thank you for the information. Very helpful.

Totally agree with you. Personally, in my state, income from the gaming business is taxed, so even if I win at 1974 world series of poker, I always indicate my income. I don't want to have any problems with the tax. Better to be a law-abiding citizen.