Anti-Money Laundering for Casinos

10000-frnCriminal organizations launder an estimated $2.5 trillion a year through financial institutions and non-bank financial institutions such as the casino industry, which is an ever growing target.  The rise of legalized gambling in cities throughout the U.S. and the high cash volume associated with gaming has increased the casino industry’s vulnerability to terrorist financing and the laundering of illegal proceeds.  If casino personnel are not trained properly, laundering cash through a casino can be very easy.

Drug traffickers launder illicit profits and ultimately integrate the funds into the legitimate economy.  Laundered drug proceeds are used to finance drug operations and other crimes, fund insurgency and terrorist organizations and promote corruption.

The gaming industry in the United States remains vulnerable to drug and other illegal proceeds.  One technique used to launder drug proceeds through casinos involves structuring cash purchases of casino chips or tokens to avoid reporting requirements and subsequently redeeming the chips for checks drawn on, or wire transfers from, casino bank accounts.  Corrupt casino employees have also facilitated the laundering of illegal proceeds through casinos.

The main reason why casinos have become so popular for laundering illegal proceeds is because virtually anything you can do in a bank (depository institution) you can also do in a casino.  There are some casinos who do not conduct wire transfers or international wires, but other than that, you can do anything else.  Because of the size of casinos and the number of people inside gambling, it becomes much easier to launder money through a casino than a bank.  For these reasons, each employee working in a casino must be properly trained and alerted to the type of activity to look for.

While a Special Agent with IRS-Criminal Investigation, I conducted AML/BSA training seminars for casinos all over Louisiana and Mississippi.  Employees had live, face-to-face training classes and learned much more than any other type of training.  Don’t gamble with your reputation and financial future.  Get the best training possible for your employees.

Casinos should know when to file a Currency Transaction Report (CTRC) and the Suspicious Activity Report (SARC).  A CTR should never be filed unless the transaction exceeds $10,000.  If you do, you are placing the financial future of the casino at risk.  If the transaction is $10,000 or less, you have the SARC available for filing.  Another reason for filing a SARC instead of a CTRC when the transactions is not in excess of $10k is because you have a “safe harbor” provision with the SARC, if filed in good faith.  You have no such protection when filing the CTRC and not required by law to do so.

The forms above cannot be filed in paper form and must be filed electronically through the BSA E-Filing System.