It involves everything a casino must do and does concerning player buy-ins, cash outs, refusals to produce ID, CTRs and SARs, and much more.

The reason I am posting this is because the other night a guy won about $8,000.00 at the table. He bought in for at least $5,000.00 that I saw. He cashed out $7,500.00.  He returns to the table and plays a few hands. Grabs $5,000.00 in purple chips and goes back to the cage. Returns back to the table and I asked him why he didn't cash them out all at one time. Told me he didn't want a CTR created, so he cashed out well under $10,000.00 and the second time gave them $5,000.00 and will get a check in a few minutes for that. So he was smiling and said, he just avoided a CTR. I told him it does not matter he is still getting a CTR filed. Years ago correct, but not no more my friend. $7,500.00 cash and $5,000.00 check equals a $12,500.00 CTR. And probably an SAR for doing the split transaction as well. He told me I had no idea what I was talking about.  (And transactions are most certainly figured cumulatively based upon the casino's 'gaming day' by the financial compliance department, no matter what the clerk at the cage or VIP counter tells you)

Please note as so many argue about and cause drama on the forums, it all starts at $3,000.00 of transactions by the player.

If you click on the link you can read it all.

Here is a copy and paste of just one little section concerning the starting threshold of $3,000.00:

(9)

(i) A separate record containing a list of each transaction between the casino and its customers involving the following types of instruments having a face value of $3,000 or more:

(A) Personal checks (excluding instruments which evidence credit granted by a casino strictly for gaming, such as markers);

(B) Business checks (including casino checks);

(C) Official bank checks;

(D) Cashier's checks;

(E) Third-party checks;

(F) Promissory notes;

(G) Traveler's checks; and

(H) Money orders.

(ii) The list will contain the time, date, and amount of the transaction; the name and permanent address of the customer; the type of instrument; the name of the drawee or issuer of the instrument; all reference numbers (e.g., casino account number, personal check number, etc.); and the name or casino license number of the casino employee who conducted the transaction. Applicable transactions will be placed on the list in the chronological order in which they occur.


The Entire Act Referencing Casinos:

https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1021

By the way, I have several letters from casinos with their inquiries to FinCIN with relation to bills-in (slots) as well as players cards (rating cards) and what is or should be considered a cash transaction. You will be amazed at the inquiries and protocols! I will post some interesting sections of those letters later today.

Good article. The gentleman you referenced above had the right idea (Just not a well-formed plan or obviously not a preplanned plan).




Continued Success,