Casino Ctr Instructions
- Casino Ctr Instructions Sheet
- Casino Ctr Instructions Online
- Casino Ctr Instructions Download
- Casino Ctr Instructions Sheet
Currency Transaction Report For Paperwork Reduction Act Notice, see page 4. 17 (04-19-11) 21 Cash in amount for individual or entity listed in item 4 $ 22 Cash out amount for individual or entity listed in item 4 $ a If entity b Unk.00.00 Amount and Type of Transaction(s). CTR due to the 24 hour rule? Or, You wire 25k to the casino, you take out a marker for 11k, color up and take the chips to the cage for redeposit, Same answer as above? Or, deposit 9900 in cash. 21 hours later you deposit 3000 in cash.
Casinos and Profiling
If one were to analyze the energy and money invested in customer profiling,Casinos would be ranked as number one. Look at all the weapons a casinohas at its disposal: Players Club Cards, Casino Credit, attached hotelrooms, valet parking, cameras everywhere, and then add facial recognition.
The biggest tool of deception is the Players Club Card. Most casinosencourage regular use of these cards, by patrons, in order to accumulatepoints, which give the player 'free stuff.' However, every timeyou present this card, that event is recorded in their monstrous database.Even if you do not present your Players Club Card when dining, purchasingshow tickets, golf, or something in a retail shop, if such a purchaseis made using a credit card, that information is captured!
Think about it. Considering the profit a casino takes in leads one tobelieve they must have the most state-of-the-art database, coupled witha tracking system to capture customer information. It's to the casinosbenefit to gather information on your interests. That way if they aresponsoring a rodeo, they can sort the records in their database in severalways to identify the most likely customers who might be enticed to attendthe event and play in the casino.
The reason for gathering this information is to enable the casino todetermine what it must do to get the customer to come back to its property,gamble, and lose more money. Taking that marketing strategy, when a playerhas accumulated points on a Players Card, he feels obligated not to 'letit go to waste.' As a result, you have a subsequent visit. Send acustomer an offer for a free room and there is a good chance you've gota return visitor. Throw in a free meal or two? The odds just increased.After all, the general mindset of the typical casino patron is, 'whynot take advantage of a free offer?'
Casino Credit
In one sentence: Don't do it! Take a look at a typical application fora credit line at a casino. After providing the casino with all that information,it goes into a database. We all know how secure databases are! Imaginea disgruntled employee who manages to keep a printed copy of a casino'sdatabase of all its premium players. Names, addresses, bank account numbers!It's an identity thief's dream!
Central Credit has provided services for the casino industry since thelate 1950s. Recently acquired by Global Cash Access, in 1998, it has increasedthe services offered as well as its ability to invade an individual'spersonal privacy.
Global Cash Access is owned by Summit Partners, M&C Internationaland Bank of America. Given this knowledge, consider that if you have abusiness relationship with any of these three co-owners, your informationis even more easily available to Global Cash Access.
Global Cash Access boasts of their identity verification system, IDNox,in their battle against identity theft. In my opinion, identity verificationsystems of this nature actually lead to more of a risk of identity theft.The reasons: First, such systems require the patron to enter much morepersonal information into a computer-based ATM or kiosk. Where do youthink that information goes? Second, you have surveillance cameras, whichare focused on these machines. Knowing the capability of these high-techcameras, do you really want to enter more personal information, whichcan be reviewed on tape by some low-paid surveillance technician? Finally,such systems require the patron to carry certain pieces of informationon his person. This is always a risk, especially in a crowded casino environment.
Global Cash Access unveiled their Arriva credit card, tailored specificallyfor the casino industry. Rather than waiting on line or seeing a casinocredit officer, the customer can go directly to an ATM machine in thecasino to achieve the same result. While the intent is to provide lowerservice and interest charges for patrons who desire cash advances on theircredit lines, it does not provide the protection against identity theft.This product is specifically geared to increase productivity and revenuefor the casino industry by making it easier for patrons to borrow money,while on the casino premises. The casino also benefits from the marketingpower of such a product. Since the patron can also use the card in thecasino's hotels, restaurants, showrooms, and retail shops, detailed informationis provided to the casino on your spending habits. This information isused for marketing purposes, to give you more incentive to patronize acasino. Sure, you can transfer points from this card to your comp accountheld with a member casino, but with all these perks you are giving thecasino more and more information about yourself. Is it worth it in thelong run?
The services offered by Global Cash Access also allows a casino's marketingdepartment to be alerted whenever a player is withdrawing cash from oneof its machines. Imagine that - you take your cash, turn around, and thereis Mr. Smiles waiting to help you lose your money!
Casino Credit Services provides casinos with a dossier of all your recordedcasino activities that have been reported to their agency. In some casino-hotels,when you check in, your name is run through a database, and the casinois alerted to the amount of credit for which you can be pre-approved.Bet you didn't know how invasive a simple process of getting a hotel roomcan be!
The marketing ability derived from the information stored in the databasesof Global Cash Access is powerful: names, addresses, phone numbers, datesof birth, social security numbers, drivers license numbers, and spendinghabits, to name a few.
Cash Transaction Report (CTR)
In addition to banks and other financial institutions, federal law requirescasinos to file a report on all currency transactions in excess of US$10,000(or equivalent in other currencies). The purpose is to fight the ongoingbattle against money laundering that is used to finance terrorist activitiesand drug trafficking. Casinos have historically been targets for thispractice.
A casino is required to file a Currency Transaction Report ('CTR')to the IRS, identifying any customer who conducts a cash transaction orseries of cash transactions totaling more than $10,000 in a gaming day.The CTR will detail the customer's name, address, date of birth, and socialsecurity number. If the customer is a regular player at the casino, hemost likely has a Player Card with an account number. If this is the case,the casino should already have this information in their system. If not,the casino employee will ask the customer for a form of government identification.If the customer refuses to provide the requested information, he willno longer be permitted to engage in further cash transactions. In mostcases, the customer will be barred from playing any casino games as well.
Notice how it is phrased 'totaling more than $10,000 in a gamingday'? If you go to a table game and buy $5,000 in chips, then laterin the day go to a different table and buy another $6,000 in chips, yourtotal buy-ins are $11,000. The casino is therefore required to identifyyou, and if they do not already have the necessary information on file,will ask you to show a government-issued identification.
Officially, they are required by federal law to identify the customerexceeding the $10,000 mark. Therefore the casino gaming staff tracksyour cash buy-ins and will attempt to identify you early on. Some casinoshave specific thresholds where they will not allow any further buy-insfor an unidentified player. It could be $5,000, $7,000, or any such amount.Here is the important distinction: It is federal law to report a cashtransaction exceeding $10,000. If you attempt to cash in $10,001 in chips,the casino cannot legally give you the cash unless they have information(obtained from a government ID) on file. The same goes for buying in forchips with cash at a table. To protect itself, a casino will make effortsto identify you prior to hitting the $10,000 mark. However, this requirementis solely dictated by internal casino procedures and not by federal law.Keep in mind that if the casino asks for your ID and you refuse, theywill keep very close tabs on your cumulative cash transactions duringthat day. They should do this because if they miss someone going over$10,000, they are subject to hefty fines.
It is not uncommon, if you are playing at a table where you bought infor $9,000 and then had a bad run, to ask to buy in for another $3,000.You will be asked for your ID. If you refuse, the casino is within itslegal rights to refuse to allow that additional buy in.
A simple way to view this is:
An ID request resulting from cash exceeding $10,000 = FederalLaw
An ID request resulting from cash less than $10,000 = InternalCasino Policy
We also need to address the term gaming day, which can differ among casinos.A gaming day (or designated 24-hour period) could be from 12:00 midnightuntil 11:59 p.m. in one casino, while it may be 7:00 a.m. until 6:59 a.m.in another. Most customers will not have knowledge of what constitutesthe casino's gaming day.
When cashing out chips at the casino cage, the same rules apply. Keepin mind that it can be perfectly legitimate to cash out different amountsat different times and exceed $10,000. However, doing so will requirethe cashier to identify you, as he must follow the law and file a CTR.Do not under any circumstances perform multiple cash outs as a deliberateattempt to avoid a CTR. This is a crime called structuring, and you canbe arrested. And, if you are in a casino with a spouse, relative or friend,you legally cannot break down your chips and have that person cash outfor you. That could be considered a form of structuring.
In order to abide by the law, casinos have a legitimate reason to identifya customer conducting cash transactions over $10,000. To protect themselvesfrom a slip-up, they implement specific procedures to identify a playeronce a certain threshold is reached. However, that threshold is an internalcasino procedure, not the law.
If your usual gaming activities exceed $10,000 you will be subject tothe above regulations. If you keep your cash activity under $10,000, youare not legally required to provide the casino with your personal information,but understand that your refusal to comply with the casino's request mightprompt them to take other actions (see below).
Suspicious Activity Report (SAR)
Financial Institutions are required by federal regulations to file anSAR when they suspect that a violation of federal criminal law or regulationis being committed or attempted and involves the money being transacted.Guess what? Casinos are required to comply with this regulation as well.Given the vagueness of the requirements, anyone can be subject to suchreporting. The actual dollar amount that warrants an SAR filing is alsovague. I've heard that banks use a $5,000 benchmark, where casinos havebeen known to use $3,000. Remember how a cash transaction in excess of$10,000 requires a CTR filing? The $10,000 number can rate you both aCTR and an SAR if someone finds you suspicious!
You are in the blind when such filings are made. The Bank Secrecy Actforbids a person filing an SAR to inform the patron that it has been sofiled. However, there are two factors where a patron is protected by thissame Bank Secrecy Act:
- The filing institution is prohibited from disclosing to other institutionsthat an SAR has been filed on a patron. In the casino business, patronsfrequently move from casino to casino while playing. A player mayeven bring chips from the prior casino to cash in a second casino.It is not uncommon for a casino to call another casino to inquireabout a suspicious patron. If this occurs, and a casino reveals toanother casino that an SAR was filed for the patron, that casino isin violation of the Bank Secrecy Act. Quite serious!
- The filing institution is not permitted to inform law enforcementauthorities that an SAR was filed on a patron. Let's take a situationwhere you are detained by casino security. Local police enter thescene. If a casino employee informs the police that they filed anSAR on the player, the casino is in violation of the Bank SecrecyAct.
Financial institutions have a 'better safe than sorry' mentalityon this issue. They
fall under the protection of the Safe Harbor Provision, where they aregranted immunity for any consequences of such transaction, provided theyfiled an SAR.
The regulations as outlined under the Bank Secrecy Act clearly definea currency transaction as the actual physical exchange of currency betweentwo parties. When you go to a casino gaming table and place $5,000 cashdown in exchange for chips, that is a physical exchange of currency. Afterthat initial $5,000 buy-in, you are using casino chips to play. Let'ssay you win $12,000 and leave the table with a total of $17,000 in chips.That is not an additional physical exchange of currency. It only becomessuch a defined exchange when you go to the cashier and exchange thosechips for actual cash.
Financial Crimes Enforcement Network (FinCen) of the U.S. Departmentof Treasury spearheads the efforts of all the law enforcement agencies,among others to fight the issues of money laundering. Under the governmentsCode of Federal Regulations (CFR), Title 31 outlines those applicableto the U.S. Department of Treasury. Within these regulations, we are discussingthree:
1. 31 CFR 103.21: Reports by casinos of suspicious transactions.
2. 31 CFR 103.22: Reports of transactions in currency.
3. 31.CFR 103.28: Identification required.
Honing in on the regulation for identification required, this is wherecasinos are attempting to gain the upper hand by misinforming their patrons.The regulation clearly outlines the requirement for identification (governmentID and social security number) for the sole purpose of filing a Reportof transactions in currency. Such a report is required to be filed forcurrency transactions, single or multiple, exceeding $10,000.00. In fairnessto casinos, they encounter players who engage in multiple cash exchangesthroughout a 24-hour period and it is difficult to keep track as to whetherthe patron has exceeded the $10,000.00 threshold. For that purpose, mostmaintain Multiple Transaction Logs, where they will either have the patron'sPlayer Card number, or in absence of that, a physical description of thepatron. At that point, it is not a legal requirement to obtain the patron'sofficial identification. The attempts made by the casino to do so arean anticipatory effort dictated by internal procedures. The tricky partis that if you do not wish to comply with the request, the casino maynot permit any further currency exchanges with you. Even though you mayhave not approached the $10,000.00 mark, the casino can implement thisas their internal policy to protect itself.
A casino is required to file an SAR if the transaction is at least $5,000(this may have been changed to $3,000) and the casino has knowledge ofor suspects that the currency involved in the exchange is related to anillegal activity. This is a very dangerous area because of its vagueness,making much subject to opinion rather than verifiable facts.
Casino Ctr Instructions Sheet
Lets say you bring in 9700 in cash to the cage at 10am deposit it and go play. . No CTR we know. You take out a 5000 marker, play and win 5001. You take the 5001 in chips to the cashier and put it back on deposit. CTR due to the 24 hour rule?
Or, You wire 25k to the casino, you take out a marker for 11k, color up and take the chips to the cage for redeposit, Same answer as above?
Or, deposit 9900 in cash. 21 hours later you deposit 3000 in cash. CTR?
Or, you saved some chips from a previous trip. Come and deposit 15k in chips, is that a CTR?
Does the cashier fill out the form every time someone gives 10k or more every time! No matter what? Does the computer automatically notify their business office upstairs to fill out a form?
Is the time clock for a 24 hour period 12:01 midnight to 12:01 midnight? Or from the time of deposit?
Don't you think in this day and age 10k cash just isn't that much to have this law in effect? Probably 50k is more reasonable. If a drug lord or some nut wants to rip off society they would be doingit with more cash than 10k in cash?
Your examples of wire transfers and chip deposits do not apply.
I do FM greater than 10k all the time and never hear anything.
Casino Ctr Instructions Online
But my understanding and the way it was explained to me by senior cage management is anytime I hand them at one time or collectively thorough out a casino day (varies around the country) per 24 hour period that is, $10,000.00 or more, a CTR will be generated. Anytime I receive amounts collectively of $10,000.00 or greater in a casino day, I will also have a CTR generated.Casino Ctr Instructions Download
As said in the above post, wires, chips, etc., any transaction NOT involving cash, means nothing.I was told by The Bellagio, if you obviously are trying to avoid a CTR and asking your buy in amounts and displaying signs of circumventing the CTR, they usually fill out a LTR which is also classified as a suspicious report, etc. Example, you won or have much more than $10k of chips and you count them out in front of the HL cashier and you hand her $9,500.00., etc.
What the Bellagio is referring to is called (IRS/Dept. of Justice) 'structuring'. Whereas the customer/player is attempting to structure various transactions to circumvent a CTR. For example, you have more than $10k in chips and you go to cash out, and then you say, 'sorry I only want to cash $9,000.00 or $5,000.00 out'. By law, they are supposed to do a LTR or a SAR (suspicious activity report) because of 'structuring'.
Fact is, if you are not ID'd, cash out amount well under $10k and don't let anyone see you hand the chips off to anyone else, etc. Come back another day and clearly well past the 24 hour mark. Not one min after the casino day. Almost ay property will still have the right to do a SAR on you.