Front Money At Casinos
Front Money Casino Definition
Front Money Accounts Casinos

Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements

This document provides guidance interpreting the requirements of the Bank Secrecy Act ('BSA') regulations¹ as they apply to the casino and card club industries in the United States. FinCEN additionally published frequently asked questions for casinos and card clubs as FIN-2007-G005 on November 14, 2007 and FIN-2009-G004 on September 30, 2009. Casinos and card clubs may continue to rely on the guidance contained in FIN-2007-G005 and FIN-2009-G004, which have not been incorporated into this publication. Section A: 31 C.F.R. § 1010.100 Casino and Card Club DefinitionsQuestion 1: Are two separately licensed, but jointly-owned tribal gaming operations, one of which is a bingo hall and the other offering casino games, both treated as casinos under the BSA regulations?

Answer 1: If a tribal government issues two separate licenses, one for a tribal gaming operation that only offers traditional bingo, and one for a tribal gaming operation that offers casino games, the former is not treated as a casino under BSA regulations, while the latter is treated as a casino under BSA regulations.² Joint ownership is not relevant to the determination. See FIN-2007-G005 (Nov. 14, 2007), Question and Answer 2, concerning the treatment of bingo. Question 2: Is a casino or a card club that cashes checks considered a money services business ('MSB')?

In the context of gambling, the term front money refers to a deposit that a player makes to their account before they begin their gaming session. In most larger casinos, this deposit is typically made at the cashier’s cage. By making a deposit, the player frees themself from the burden of having to carry around stacks of chips or currency. This is typically done for the sake of convenience and security.

Casino Money Laundering – Explained and Discussed in Detail. Author: Teresa Chang. A massive stain on the industry is casino money laundering, it runs rife in many unregulated markets around the world, contributing to organized crime and fuelling a black market of drugs, weapons, human trafficking and many more illicit commodities. Front money Guests may deposit funds with the main casino cashier cage in order to draw funds at the game of their choice. Cash equivalents such as cashier’s checks, certified checks or wire transfers (subject to verification) in addition to cash or chips, may be placed on deposit for withdrawal.

Answer 2: No. A casino or a card club that is duly licensed or authorized to do business as such, and has gross annual gaming revenue in excess of $1 million, is subject to the requirements applicable to casinos or card clubs, even if a casino or card club does its own check cashing. A casino or a card club is not required to comply with rules specific to MSBs.³ Section B: 31 C.F.R. §§ 1021.311(a) - (c) and 1021.313 Currency Transaction Reporting RequirementsQuestion 3: Can a casino comply with currency transaction reporting requirements by using a 'two-strike' system to obtain identifying information for customers purchasing chips in multiple transactions?

Answer 3: FinCEN is aware that some casinos use a so-called 'two-strike' system (or possibly a similarly designed system) to obtain customer identifying information related to reportable currency transactions involving multiple chip purchases during a gaming day. Rather than obtaining information directly from a customer during a transaction, the casino relies upon computer or other pre-existing internal records to identify transactions and obtain the identifying information (e.g., Social Security Number, an address) needed to complete a currency transaction report. If the necessary identifying information is absent or incomplete, the casino will file an incomplete report and enter the name of the customer into a computerized database.

When the same customer returns to the casino on another gaming day and purchases $5,000 or more in chips with currency, the casino will check a computerized database to determine if an incomplete report had previously been filed. The casino will ask the customer for any omitted identifying information. If the customer refuses to provide the information and the customer purchases chips for less than $10,000, the casino will wait until the customer's currency activity exceeds $10,000, at which point it will again request identifying information. If the customer refuses to provide the information, then the customer is banned from further cash buy-ins until the information is produced or until the expiration of six months.

A 'two-strike' system could result in the filing of two incomplete currency transaction reports. The casino has knowledge that the same customer has conducted transactions in amounts aggregating to more than $10,000 during a single gaming day. A casino has 15 gaming days to file a complete report. If a casino has a reasonable opportunity to obtain identifying information from a customer, but instead relies on inaccurate or incomplete information in pre-existing internal records, the casino has not complied with the regulations.Question 4: Is a card club required to create and retain records of all currency transactions related to Kum Kum betting?

Answer 4: The regulations implementing the BSA require card clubs to create and to retain records of all currency transactions by customers, including records in the form of currency transaction logs and multiple currency transaction logs.⁴ This requirement applies to card clubs that offer the practice of Kum Kum betting and banking.⁵ In Kum Kum betting, bets are broken into a ratio or evenly split among individuals in a partnership, and wins or losses are divided among the individuals. An individual placing a Kum Kum bet must exchange currency for chips with a card club dealer or chip runner before a Kum Kum bet is accepted.

The regulations require a card club to file a currency transaction report for each transaction in currency involving cash in or cash out of greater than $10,000.⁶ An individual purchasing chips with currency is conducting a cash-in transaction. Card clubs completing a currency transaction report must identify persons on whose behalf transactions are conducted and must aggregate transactions based on the identities of these persons. An individual placing a Kum Kum bet places the bet on behalf of each individual in the partnership. Card clubs must have risk-based procedures to identify Kum Kum bets and the individuals involved in the bets.

Question 5: Can a casino rely on an ITIN as a means of verifying identity?

Answer 5: No. The Internal Revenue Service ('IRS') issues an Individual Taxpayer Identification Number ('ITIN')⁷ to individuals for use as a tax processing number. The IRS issues ITINs to foreign nationals and others (both resident and nonresident aliens) who have Federal tax reporting or filing requirements and do not qualify for Social Security numbers. The regulations require casinos and card clubs to verify the identities of these individuals by examining a passport, alien identification card, or other unexpired official document evidencing nationality or residence.⁸ Casinos should not rely on ITINs in verifying identity or responding to items in a currency transaction report that elicit information on verification of identity, since ITIN applicants are not required to provide identification documents.

Question 6: What transactions are exempted from currency transaction reporting requirements?

Answer 6: A casino is not required to report currency transactions with:

Certain domestic banks;⁹ or
Dealers in foreign exchange or check cashers, so long as the transactions are conducted pursuant to a contractual or other arrangement covering the financial services described in 31 C.F.R. §§ 1021.311(a)(8), (b)(7), and (b)(8).

In addition, a casino is not required to report the following transactions:

Cash-ins to the extent the same physical currency was wagered previously in a money play on the same table game without leaving the table;¹⁹
Bills inserted into electronic gaming devices in multiple transactions (unless a casino has knowledge pursuant to 31 C.F.R. § 1021.313);
Cash outs won in a money play, to the extent it is the same physical currency wagered; or
Jackpots from slot machines or video lottery terminals.

Question 7: Can a casino subtract cash-out transactions from cash-in transactions when aggregating multiple transactions?

Answer 7: No.

Front Money At Casino