Address 8: No. Whenever a gambling establishment or credit pub have acquired actual experience in good reportable currency exchange, it must get the identity recommendations (including consumer title, long lasting target, and you can Personal Shelter Amount (“SSN”)) wanted to document an entire and you will exact CTRC, and then make certain title and you will address “before concluding the order.” Whether your customer’s condition driver’s license doesn’t incorporate a personal Shelter Matter additionally the consumer will not bring a paper Social Cover Matter cards provided by the Social Safeguards Government, a casino or card club can enter a verbally offered SSN toward a CTRC. In addition to, FinCEN knows that a casino have the client complete an Internal revenue service Setting W-nine, Obtain Taxpayer Identity Amount and you can Degree, 29 to acquire another person’s best Taxpayer Personality Count thirty-two or, whether your consumer provides a deposit otherwise borrowing account for the casino, the fresh new casino usually comment the new membership to find the SSN just like the brand new SSN needs at that time your membership is exposed. 33 In all circumstances, a casino otherwise a cards pub have to file an excellent CTRC getting reportable transactions with all the needed determining advice that it enjoys obtained from a customers, bodies ideas they maintains and you will/or other affirmed internal ideas. 34
Question 9: Are two alone registered, but as one-possessed riverboat gambling enterprises that are functioning from the same pier and you can sharing certain pointers assistance, necessary to aggregate money purchases of the same customers you to definitely took place in the each other gambling enterprises?
F.R
Respond to nine: No. A couple riverboat gambling enterprises that are under well-known possession and you will popular management, show certain guidance possibilities, maintain equivalent accounting and you will inner handle methods, otherwise utilize the same docking establishment, however, having independent certificates, commonly called for significantly less than 30 C. § (b)(2) and you may (c)(3) so you’re able to aggregate and you may statement buyers money purchases one to taken place within each other business. 35 However, for a few riverboat gambling enterprises with automated analysis operating possibilities that will be directly incorporated, automatic applications for conformity to your BSA must provide into the entry to these expertise to help in to be certain compliance with determining deals that seem is doubtful and that try conducted ranging from the 2 casinos because of the recognized users thirty six (age.grams., so you’re able to evade the newest $10,100 revealing requisite thanks to structuring). 37
Concern ten: Are a casino needed to document a good CTRC into the consumer jackpot wins regarding online casino games other than position jackpot otherwise clips lotto critical victories?
Respond to ten: Yes
A casino is needed to document a good CTRC with the customer jackpot wins paid-in currency from casino games apart from slot jackpot otherwise clips lotto critical gains. 38 They truly are certainly most other game, bingo (traditional), 39 Caribbean stud casino poker, keno, or let it experience casino poker. 40 Such deals may need to end up being aggregated with other bucks away transactions.
Respond to 11: Yes, gambling enterprises will get utilize Point 314(b) 41 information discussing to the office along with her to determine currency laundering and violent money. Together with, casinos normally utilize Point 314(b) information discussing with depository organizations and cash attributes companies. Section 314(b) as the used by the 31 C. § , kits a safe harbor away from responsibility for a lender or association regarding financial institutions you to willingly chooses to show guidance that have other creditors for the true purpose of distinguishing and, where compatible, reporting money laundering otherwise violent interest (if necessary notice, confirmation and you can suggestions protection is within personal loan Florida set). Section 314(b) it permits sharing information relating to transactions you to a lending institution suspects will get involve the latest proceeds of one or maybe more specified unlawful affairs placed in 18 U.S.C. §§ 1956 and you can 1957, which includes a wide range of deceptive or other crimes. 42 The secure harbor provided of the Point 314(b) is just accessible to financial institutions that will be needed to pertain an enthusiastic anti-currency laundering program, that has, eg, depository organizations regulated by the a national practical regulator, 43 casinos, and cash functions organizations. 44
