§ 1021.210 Anti-money laundering program requirements for casinos.

Hard money lenders will typically finance only a percentage of the purchase price of the casino— usually 65% to 75% (Loan to Value Ratio). Since the casino will produce income, a loan can be based on the value of the property plus its income producing potential. Interest rates might possibly run anywhere from 8% up; may initially be fixed. Once approved your casino credit account is available 24/7.Not available at all properties. Subject to credit approval. Must apply for a minimum amount of credit, which varies by property.Online application not available for all properties. See Caesars Rewards Center for application. The anti-money laundering compliance program requirement obligates a casino or card club to use all available information to determine a customer's name, address, and Social Security number 19 from any existing information system or other system of records for a reportable multiple transaction summarized through 'after the fact aggregation.

Once approved your casino credit account is available 24/7.Not available at all properties. Subject to credit approval. Must apply for a minimum amount of credit, which varies by property.Online application not available for all properties. See Caesars Rewards Center for application.

(a)Requirements for casinos. A casino shall be deemed to satisfy the requirements of 31 U.S.C. 5318(h)(1) if it implements and maintains a compliance program described in paragraph (b) of this section.

(b)Compliance programs.

(1) Each casino shall develop and implement a written program reasonably designed to assure and monitor compliance with the requirements set forth in 31 U.S.C. chapter 53, subchapter II and the regulations contained in this chapter.

(2) At a minimum, each compliance program shall provide for:

(i) A system of internal controls to assure ongoing compliance;

(ii) Internal and/or external independent testing for compliance. The scope and frequency of the testing shall be commensurate with the money laundering and terrorist financing risks posed by the products and services provided by the casino;

(iii) Training of casino personnel, including training in the identification of unusual or suspicious transactions, to the extent that the reporting of such transactions is required by this chapter, by other applicable law or regulation, or by the casino's own administrative and compliance policies;

(iv) An individual or individuals to assure day-to-day compliance;

(v) Procedures for using all available information to determine:

(A) When required by this chapter, the name, address, social security number, and other information, and verification of the same, of a person;

(B) The occurrence of any transactions or patterns of transactions required to be reported pursuant to § 1021.320;

(C) Whether any record as described in subpart D of part 1010 of this chapter or subpart D of this part 1021 must be made and retained; and

(vi) For casinos that have automated data processing systems, the use of automated programs to aid in assuring compliance.

FIN-2009-G004

Frequently Asked Questions Casino Record keeping, 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. We additionally published frequently asked questions for casinos and card clubs as FIN-2007-G005 on November 14, 2007. Casinos and card clubs may continue to rely on the guidance contained in FIN-2007-G005, which has not been incorporated into this publication.

Section A: 31 C.F.R. § 103.11 Casino and Card Club DefinitionsQuestion 1: Do Nevada slot route operators operate 'casinos' for purposes of rules implementing the BSA?

Answer 1: A Nevada slot route operator is a gaming licensee who, pursuant to a participation agreement, owns and maintains slot machines at three or more business establishments. The business establishments are owned and operated by other persons.² While it is common for Nevada slot route operators to lease space from a property owner (usually referred to as a 'space lease agreement'), and to pay a monthly rental payment to such a landlord, the Nevada slot route operator may have its own 'nonrestricted' license to conduct gaming on the premises.³ A Nevada slot route operator with a 'nonrestricted ' license to conduct gaming at a business establishment would be operating a 'casino' at the business establishment for purposes of FinCEN's BSA rules,⁴ if gross annual gaming revenue of its operations at the business establishment exceeds $1 million.⁵ Question 2: Are gaming or gambling establishments with gross annual gaming revenue of $1,000,000 or less subject to any BSA requirements?

Answer 2: Yes. The requirement to file a FinCEN/IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, for currency⁶ received in a trade or business applies to businesses that are not casinos or financial institutions under FinCEN's rules. The term 'cash' for Form 8300 reporting purposes includes coin and currency of the United States or any other country, and may include cashier's checks, bank drafts, traveler's checks, or money orders received over $10,000 in one transaction (or two or more related transactions) during a 12-month period.⁷ For purposes of illustration, the following gaming and gambling establishments or nongaming related businesses normally would be subject to Form 8300 requirements:⁸ (i) casinos or card clubs with gross annual gaming revenue of $1,000,000 or less; (ii) tribal bingo halls, off-track betting parlors, greyhound tracks, horse race tracks, or (iii) a casino hotel, gift shop, cater/banquet service, conference/seminar facilities,¹⁰ etc. The BSA prohibits any person from structuring transactions to evade reporting or recordkeeping requirements under the BSA.¹¹ Section B: 31 C.F.R. § 103.22 Currency Transaction Reporting RequirementsQuestion 3: What is the definition of a gaming day and what effect does it have on aggregating a customer's reportable currency transactions?

Answer 3: A gaming day is defined as the normal business day of a casino or card club. If a casino or card club offers 24-hour gaming, the term 'gaming day' means that 24-hour period by which a casino or card club keeps its books and records for business, accounting, and tax purposes.¹² A casino or card club must have only one gaming day, which is common to all its gambling operating divisions or departments. Maintaining one gaming day facilitates the aggregation of transactions for purposes of currency transaction reporting.Question 4: Is a card club required to file FinCEN Form 103, Currency Transaction Report by Casinos ('CTRC'), for customer currency buy-ins at poker games?

Answer 4: Yes. When a customer at a poker table buys-in¹³ for more than $10,000 in chips with currency, in a single transaction or a series of related transactions in the same gaming day, a card club must assure compliance with CTRC requirements for such transactions. The same would apply to other non-house banked card games (e.g., games commonly referred to as 'California Games'¹⁴ in certain card clubs or card rooms). If the card club has knowledge of the transactions, it must report the transactions on a CTRC.¹⁵

A card club must implement a program reasonably designed to assure compliance with the BSA.¹⁶ For the reporting of transactions in currency, regardless of whether a card club has a multiple transaction log, it must have a system of internal controls, procedures for using all available information to determine and verify, when required, the name, address, Social Security or Taxpayer Identification Number, and other identifying information for a person, as well as train personnel.¹⁷ https://clevermad.amebaownd.com/posts/23087180.

In addition, BSA rules impose record retention requirements on card clubs.¹⁸ These requirements are independent of the requireme

Casinos Requirement For Lending Money