Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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7/9/2007 Currency Transaction Reporting Rules Lighten Some Requirements for Casinos

Final rules modifying currency transaction reporting requirements for casinos attempt to lighten the reporting load that has been placed on casinos and card clubs. Now exempt from such reporting, for instance, are transactions between a casino and a currency dealer or exchanger, or between a casino and a check casher, “so long as such transactions are conducted pursuant to a contractual or other arrangement with a casino.” FInCEN noted that requiring a casino to file CTRs for such transactions would result in duplicative reports, since currency dealers and exchangers, and check cashers, would already be required to file CTRs on the transactions. The casino industry did not get all the relief it hoped for in the final rules. For instance, bills inserted into gaming devices are still reportable, though not in multiple transactions unless the casino has knowledge of the player’s activities. The final rules will be discussed in detail in the September issue of the Monitor. The Checklist for Casinos being posted on the website associated with Money Laundering, Terrorism and Financial Institutions ( will reflect the changes in these final rules.

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