Money Laundering, Terrorism & Financial Institutions
Published by Civic Research Institute,

USA PATRIOT Act Monitor News Release: New SAR for Casinos, Card Clubs
3/25/2003 7:21:25 AM Eastern Standard Time

FinCEN has released a new Suspicious Activity Report, form and instructions, for casinos and card clubs. The new SAR, FinCEN Form 102, replaces TD F 90-22.49 [see MLT Chapter 2.6]. The instructions note that casinos and card clubs may rely on their internal records, including copies of federal forms with verified customer information, to identify the subjects of a SAR. Such records may include credit, deposit, or check cashing account records; or a filed IRS Form 8362, (Currency Transaction Report - Casino), IRS Form 8852, (CTRC-Nevada), IRS Form W-2G, (Certain Gambling Winnings), IRS form W-9 (Request for Taxpayer Identification Number and Certification), or any tax or other form with customer information. If casinos do not have verified identification information on the customer, they should consult other internal records (player rating records, slot club records, etc.). If the subject is an “unknown,”casinos should consider using whatever other internal sources are available to obtain customer identification (hotel registration, show reservations, credit card numbers, riverboat casino reservation records, etc.). The new form and instructions can be downloaded from the FinCEN website.


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