πŸ€‘ Examination Techniques For Bank Secrecy Act Industries | Internal Revenue Service

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These monetary instrument logs are usually kept in the casino cage. A sample of the multiple transaction log is shown in figure A sample monetary.


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In addition, because AML programs are risk based and casinos have different risk profiles, individual multiple monetary instruments for a jackpot or wager win. Summaries, multiple transaction logs, Monetary Instrument Logs, Check.


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These monetary instrument logs are usually kept in the casino cage. A sample of the multiple transaction log is shown in figure A sample monetary.


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The Monetary Instrument Log, or MIL, tracks patron transactions using monetary instruments. Monetary instruments include, but are not limited to: personal.


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Page 3 of Monetary/Negotiable Instrument Log. Risk-based AML compliance efforts are essential to the casino industry. Since


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The Details: Title 31 Requirements & Compliance for Casinos and Card Clubs currency; funds; checks; investment securities; credit; other monetary instruments of thumb, transactions that are $2, - $3, are recorded in these logs.


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These monetary instrument logs are usually kept in the casino cage. A sample of the multiple transaction log is shown in figure A sample monetary.


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FinCEN Guidance: Casino or Card Club Compliance Program. Assessment (​June 30, ). 6. FinCEN Assessment of Civil Monetary Penalty against CG not maintained on the casino's negotiable instrument log, and the.


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Monetary Instruments Log (MIL) (also known as a NIL) – A term used by casinos for the separate record containing a list of each transaction.


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The Details: Title 31 Requirements & Compliance for Casinos and Card Clubs currency; funds; checks; investment securities; credit; other monetary instruments of thumb, transactions that are $2, - $3, are recorded in these logs.


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Most U. Marker Redemption - The redemption or paying off a previously issued marker by a customer. Casinos as defined in 31 CFR If one corporation has three casinos each with the same EIN but with three separate casino licenses then each casino is a separate financial institution. The representative can be a junket operator or an employee of the junket operator. It is duly licensed or authorized as a casino or card club in the United States or a class III tribal casino with or without authority to operate as a tribal class II casino and. Casinos vary in size and sophistication from small one owner gambling parlors, offering a limited number of games and services, to large corporate luxury mega facilities offering a full range of games, services and entertainment. Authority to examine casinos to determine compliance with the BSA reporting, recordkeeping, and compliance program requirements has been delegated by Treasury to the IRS in 31 CFR Backline Betting - A type of betting that occurs when a customer, who is standing behind a seated player, places a bet or wager on the betting circle for a specific hand on which a seated player also is wagering. Bill Stuffing - A customer placing currency in a slot machine, then cashing out after minimal or no play. Program Owner. However, as with other financial institutions, casinos provide a wide range of financial services to their customers including:. Transactions between customers and foreign branch offices are not subject to BSA reporting and recordkeeping requirements. Upon completion of the session play the balance is settled in the form of a marker. Assist the financial institution to understand the BSA requirements and encourage compliance, and. A lammer is placed on the table while the chips are given to the customer. Also, larger casinos may maintain satellite cages in slot areas, high roller areas or in the betting parlors. Also, a "comp" can be in the form of currency. Complimentary Comps - Complimentary items or "comps" typically are goods or services that a casino gives to a customer, at reduced or no cost, based on significant play and can include beverages, coupons, or other representations of money for use in wagering, beverage, food, entertainment, merchandise, lodging, show ticket and ticket to special events, or transportation for example, airplane ticket, car rental. Director, Examination - Specialty Examination is the executive responsible for BSA examination operational compliance. FinCEN re-delegated responsibility for assuring civil compliance with the law to various Federal agencies including the Internal Revenue Service. The gambling establishments do not risk any of their own money. The funds will be held in a front money deposit account until the junket arrives at a casino. Transactions at these branch offices specific to a casino licensee are considered to have occurred by, through or to the licensee. This type of betting is more common at card clubs. Typically, the representative will send a wire or money transfer of the total funds that the junket players intend to gamble to a casino's domestic bank or a money transmitter located on the casino's premises. Even though each separate casino license defines a casino as a financial institution for BSA purposes, some casinos may have branch offices to accept payments for debit and credit accounts. An effective method to detect this is by reviewing computerized customer records such as player ratings to determine potential suspicious activity. MTL - Casino documents used for recording and keeping track of customer currency transaction activity above a given dollar threshold. These four factors, when multiplied together, produce the theoretical win for a casino. Bettors are essentially betting against each other, which means that the losers pay the winners. The most common reference is for individuals who:. Gaming Day - The normal business day of the casino by which it maintains its books and records for business, accounting, and tax purposes. Player Rating System - A manual or computerized system of tracking customer gambling activities at various gaming departments Tables Games, Race and Sports, Keno, Poker, and Bingo based on physical observations by casino employees. In a pari-mutuel system of wagering, gambling establishments pool all customer wagers on the outcome of various racing and sporting events. It is usually a percentage or a flat fee that is taken from the pot after each round of betting. Casinos award comps to gamblers based on a percentage of theoretical win. The extra players that stand behind each seat position are known as "backline betters". It is calculated using the following four factors:. In most jurisdictions junket operators are not casino employees and thus are not subject to the same degree of licensing oversight by State gambling regulators; nonetheless, some background screening is done on junket operators. Barred Player List - A list of casino customers barred from future gambling activity such as card markers, other casino cheats, thieves, and card counters. Junket Representative - A person who is responsible for organizing a group of players a junket to gamble at a casino. Rim Credit - An extension of credit, noted on a rim card for faster session play. Bill Validator Acceptor - An optical mechanical device attached to an electronic gaming device such as a slot machine or video lottery terminal that accepts U. The most common method is based on theoretical win, which is the amount a casino expects to win from a customer. The definition of a casino as a financial institution includes any branch office. These branch offices can be authorized to conduct wire transactions for customers which would be considered as conducted by, through or to the casino. Chip Redemption - The exchanging of chips by a customer for cash, casino check, or outgoing wire transfer. Almost all casinos maintain a barred patron list containing the names of customers who did not provide identification credentials after completing reportable currency transactions. Although backline betting makes it difficult to track customer wagers at the gaming table, a card club is required to have a procedure in place to identify such transactions. Rake - The money a casino charges for each hand of poker. All examiners must perform their professional responsibilities in a way that supports the IRS Mission. Minimal Gaming or Minimal Play - A term that can apply to many different situations in a casino environment. A casino may have only one gaming day common to all its divisions. Whenever the term casino is used in the regulations or in this IRM, the term expressly includes card clubs, and the same requirements therefore apply, unless a different treatment for card clubs is explicitly stated in 31 CFR Part Unlike other financial institutions, which exist solely for conducting financial transactions, casinos primarily function as entertainment and recreational facilities. Shill - A casino employee who actively plays in a table game for the casino, club or the house. Then cash out the remaining chips either by the gamblers or their agents. Casinos use a variety of methods to award complimentary services, or comps to attract and retain their customers.

The material covers the full examination process from monetary instrument log casino pre-planning stage to closing. Drop β€” "Drop" in table games, is the total amount of cash or cash equivalents plus paper credits for example, markers that a dealer puts in the table drop box which were exchanged for chips or plaques.

Player Rating - A monitoring system a casino uses to rate and track the gaming activity of a single player.

Buy-in β€” The amount of monetary instrument log casino a player uses to purchase casino chips when commencing play.

Usually seen at a Baccarat table to fill empty seats, until more real players join the game.

Chip Walk - A casino term for chips that a customer leaves a gaming table with at the end of play. All cases are subject to factual development. The betting can occur at racetracks, OTB facilities, tribal, racinos, frontons, on Internet platforms, and interactive television platforms. Examiners should adapt the procedures in this section, as necessary, to each situation. Some branches may even be a residence for a junket operator, marketing representative or an independent agent who has been delegated authority by a casino to accept funds for deposit or as credit payments from customers. A slot player rating system is a computerized system used to track customer gaming activity at the slot machines using "Slot Club Membership Cards" inserted into the machine. Thus, the wagering may be conducted at a location other than the racetrack or fronton where the race or jai alai match, respectively, is held. Pari-Mutuel Wagering - Wagering conducted pursuant to licenses granted in the US by state governmental agencies on various sports, including horse racing, greyhound racing and jai alai that occur at racetracks, racinos, and frontons. Also, the drop refers to the removal of the slot machine and table game drop boxes that are transported to the hard and soft count rooms, respectively. A buy-in can occur in cash, credit, or as a deposit withdrawal. These activities are conducted to make the currency appear as a legitimate source of income. Another example would be if a person cashes a check at the casino cage but never gambles they would still be considered a customer of the casino. A card club cage operates, for the most part, as does a casino cage except that it does not offer token sales and redemptions because there are no slot machines. Pursuant to a memorandum of agreement with the Department of Treasury, certain casinos in Nevada were exempted from direct application of BSA recordkeeping and currency transaction reporting requirements. Lammer - A button or chip distinguishing the amount of credit being granted to a customer. This section discusses basic information about how each unique financial institution operates, books and records commonly found at each financial institution, and examination and auditing techniques for each financial service offered. Determine whether the financial institution is following all recordkeeping and reporting requirements,. Determine whether the financial institution has established and implemented an effective anti-money laundering AML program,. In addition to a gambling casino, the larger resort type casino complex may include hotel facilities, restaurants, bars and lounges, theaters and showrooms, sports and health facilities, convention space, and various exclusive shops and stores. Subsequent transactions between a foreign branch office and a U. Such machines are designed to reduce time to pay out slot jackpots to customers and improve productivity. Policy Owner. Winners divide the total amount bet in the wagering pool in proportion to the sums that customers have wagered individually on each racing event, after the operator deducts its takeout which constitutes the gross revenue of the pari-mutuel business that is used to pay operating expenses, contributions to purses, taxes, including pari-mutuel taxes, interest, debt service, pension benefits, and any other charge against income. Some examination steps will be consistent for all financial institutions, others will be unique to the financial service provided. This requires examiners to provide top quality service and to apply the law with integrity and fairness to all. Primary Stakeholders. This internal account is offered to allow a customer to deposit with a casino funds to be gambled or won. The requirements of the BSA apply only to transactions taking place between the gambling casino and its customers, however, 31 CFR For example, if a person wires funds to a casino to be placed in a front money account but never gambles, they are still considered to be a "customer" of the casino. A customer would have to sign a marker before a casino will extend credit, which insures that a marker is treated as a personal check. Currently, kiosk machines do not require a customer who has a slot club account card to use it to conduct transactions. The latter two factors, which are used to compute the "player" rating is monitored, recorded by a casino supervisor typically on a player rating card, and entered by a pit clerk into a computerized tracking system. Chips also known as, Checks, Tokens - A gaming instrument issued in various denominations and used as a substitute for currency at table games in a casino. These branch offices may be shared with other related properties and may operate under a different legal name and EIN. Front Money Deposits and Withdrawals - Money deposited by a customer into a personal casino account at a cage that a customer could later withdraw at a gaming table in the form of chips to bet or wager with after signing a so-called "front money marker" against the deposited funds , electronic gaming devices in the form of credits or access cards , or later at a cage in the form of casino check, currency, money transfer, and other similar items.