Can You Leave A Casino With Chips

Casinos in the United States which generate more than $1,000,000 in annual gaming revenues are required to report certain currency transactions to assist the Financial Crimes Enforcement Network (FinCEN) of the Internal Revenue Service (IRS) in uncovering money laundering activities and other financial crimes (including terrorist financing).

  1. Can You Leave The Casino With Chips
  2. Can You Leave A Casino With Chips Instead

Although Title 31, also known as the Bank Secrecy Act, was originally focused on financial institutions, criminal use of banking services located within casinos created a need for additional regulations that were specific to casinos. Because large sums of currency are transacted through slot machines, gaming tables, automatic change machines, retail operations and the cage (banks), and with high frequency, the regulations were targeted at transactions in excess of $10,000. Casino regulation has been a topic of debate, prompting the United States Senate to have a hearing before the United States Congress in which Title 31 topics were discussed through testimony by industry experts such as Grant Eve, CPA and partner at Joseph Eve, Certified Public Accountants and Ernest Stevens Jr., Chairman of the National Indian Gaming Association.[1]

Transaction reporting[edit]

Currency transactions that occur within a single Gaming Day (the normal 24-hour period that any casino uses for accounting and business reporting), whether the currency is paid into the casino, paid out, or exchanged (in the case of foreign currency exchanges), in excess of $10,000 requires the completion of a Currency Transaction Report (CTR, FinCEN Form 112) and must contain enough information to accurately identify the individual(s) transacting the currency.

I brought back a $1 chip from Luxor, Paris and Bellagio. I glued them onto a Vegas postcard and hung it on our 'memories' board. You shouldn't be allowed to take some of the chips off the table. If you wanna leave then take all your chips and leave. If you're allowed to take some of your chips off the table, are you really.

For example, if a man walks into a casino and stops at the blackjack tables and buys into the game for $12,000 (using cash), a CTR must be completed by the casino and filed with the IRS. In this example, currency is paid into the casino in the form of cash and happened within the unique 24-hour Gaming Day of the casino.

Can you leave a casino with chips instead

Here is an example of a cash out transaction: the established Gaming Day of a certain casino begins at 1:00am and ends at 12:59am. At 6:30am, a woman takes $6,400 in slot machine tickets to the main cage of the casino and requests payment in all $20 bills. Later that day, at around 7:10pm, the same woman approaches another cash cage on the opposite side of the casino and exchanges $4,000 in blackjack chips for cash. Because $10,400 was paid out in cash to a single individual in a single Gaming Day, a CTR must be filed by the casino to report the Cash Out transaction, because it is above the $10,000 threshold.

Because multiple transactions are aggregated for the purpose of Title 31 reporting, casinos create tracking programs to identify large transactions and automatically aggregate them in real time to ensure that they are compliant with the regulations.

Suspicious activity[edit]

Many criminals, such as those interested in tax evasion and money laundering, have researched the Title 31 requirements and have created a number of strategies to avoid detection of their activities by circumventing the reporting requirements. When these activities are discovered, casino staff are required to file a Suspicious Activity Report (SAR, FinCEN Form 114) to report the suspicious activities. Because there are many types of suspicious activities, it is required that casino personnel receive Title 31 training to avoid penalty and remain compliant.

Two of the most popular strategies for circumventing CTR reporting are structuring and minimal gaming.

Structuring[edit]

Because the $10,000 per gaming day CTR threshold is part of the Bank Secrecy Act, a criminal may seek to evade being recorded on a CTR by breaking a transaction over $10,000 into multiple smaller transactions, which is known as structuring. Single and multiple currency transactions in excess of $10,000 (in a single Gaming Day) are reported to the IRS. To track multiple transactions, many casinos record transactions as low as $3,000 (and lower) to ensure that they remain compliant with the CTR requirements. Again, criminals (including those interested in tax evasion) may break up their transactions into several, smaller transactions to avoid detection.

For example, conducting three transactions of $4,000 is more than $10,000, which is the threshold of reporting a CTR. If the casinos did not track multiple transactions, the individual might be able to circumvent the reporting of their transactions. However, because most casinos track transactions of $4,000 (and lower), structuring this $12,000 transaction into three, smaller transactions would not prevent a CTR from being filed. And, while it may be possible to break up $12,000 into 20 individual transactions of $600 each, casino personnel also maintains awareness of this tactic and would likely detect the numerous trips to the cage to perform similar transactions.

Minimal gaming[edit]

Another type of suspicious activity is related to money laundering, where a casino patron may put large amounts of money in play, but gambles very little before cashing out.

For example, a bank robber steals $50,000 from a large bank. Most banks mark cash with exploding dye or sequential numbering of the large bills. To avoid being apprehended, the bank robber needs to exchange the stolen money for money that cannot be traced back to the robbery. In this situation, a bank robber may put $1,000 in $20 bills into a slot machine and spin twice before cashing out. Whether the slot machine pays the bank robber in coins or a slot ticket is irrelevant because the traceable money is in the machine and the bank robber will effectively receive 'clean' or 'laundered' money.

Both of these situations are suspicious, as defined by Title 31 regulations, and require a completed SAR by the casino, within a specified period of time.

Involvement of Agents[edit]

Two or more individuals handling the same currency bankroll are commonly referred to as 'agents' by the casino. An example of this would be individuals purchasing chips and dividing them amongst themselves. Agents cashing out chips or making currency transactions on behalf of one another are also popular examples of agent activity. Since agents handle the same bankroll, they essentially become entities and their transactions must be recorded together. All parties involved in agent activity must submit proper identification and complete the required IRS forms when their COMBINED transactions reach over $10,000 in a gaming day. While agent activity can sometimes occur with legitimate transactions (e.g. a husband cashing out his wife's slot vouchers so she can continue to play), agent activity is highly suspicious because it allows individuals to structure their transactions below the $10,000 to avoid being documented to the IRS.

Involvement of casino staff[edit]

It is illegal for an employee of the casino to assist a casino patron in circumventing the reporting requirements of Title 31. Such circumvention can include notifying patrons that they are nearing reporting thresholds, disclosing the time that the Gaming Day ends, and neglecting to report suspicious activity. A casino employee that has been found to have circumvented Title 31 can be assessed civil and criminal fines, in addition to incarceration.

References[edit]

  1. ^United States Senate Committee on Indian Affairs (November 17, 2011). 'The Future of Internet Gaming: What's at stake for tribes?'. One Hundred Twelfth Congress First Session.

Can You Leave The Casino With Chips

Retrieved from 'https://en.wikipedia.org/w/index.php?title=Casino_regulations_under_the_Bank_Secrecy_Act&oldid=974176088'

If you visit casinos, in Las Vegas or elsewhere, you’ve seen these items before. You just haven’t seen them like this!

1. Craps Stick

This device is used by the “stickman” (yes, it’s a “stickman,” even when it’s not a man) to retrieve the dice. They may also be used by shady stickmen to “short stick,” which means pushing the dice to a female gambler just far enough so she has to lean forward to pick them up, cleavage-wise.

2. Paddle

On casino table games, there’s a slot where your money goes and never comes back. The paddle is used to push the money through the slot.

A paddle is also called a “plunger.”

Here’s a normal view of a paddle so you know one when you see one.

This paddle is useless in a canoe, so don’t even think about it.

3. Cup Holder

These handy devices keep your cocktail safe.

Casinos hate spilled cocktails on their fancy felt, so cup holders serve a very useful purpose.

Can You Leave A Casino With Chips Instead

Casino cup holders have a special lip that goes under the table’s arm rest, a little insurance to keep us from being whacked by pit bosses.

4. Dice

There’s nothing like the feel of dice in your hands. Just don’t switch hands while you’re shooting at craps. Casinos prohibit hand-switching to avoid the possibility of cheating.

The spots on dice are called “pips.”

5. Discard Tray

This is where your cards go after they’ve been used. Discard trays are often translucent and red to help casinos catch players marking their cards.

Cheaters use inks or “daubs” which can be detected by viewing cards through the discard tray.

Amazing the things we take for granted when we see them in a casino.

Discard trays are usually affixed to the table with screws, but we’ve always had a couple of screws loose.

6. Gaming Chip

Casino chips are also called checks, cheques or casino tokens. There are several reasons casinos use chips rather than cash, but the main reason is customers gamble more freely when they use chips rather than cash. Surprise!

Many casino chips are made from the same kind of clay used to make kitty litter.

7. Felt Brush

Brushes are used to keep felt tables clean in casinos. Leave brushes off our list? We bristle at the idea.

Felt brush bristles are made of nylon, a family of synthetic polymers known as aliphatic polyamides. Yes, we knew that off the top of our head, thanks.

Here’s another look at the typical felt brush.

A “Brush” can also be a poker room employee who helps players with chips, seating and other tasks. The name was inspired by the brushes used to clean debris from the tables.

8. Roulette Marker

When a number is called in roulette, the dealer places a marker on the number. Players are asked to wait until the marker is removed before retrieving their winnings.

Roulette markers come in a variety of styles and materials.

A roulette marker is also called a “dolly.” That’s because the profile of some markers looks like a doll.

9. Craps On/Off Puck

A craps puck, also called a “buck,” marks the number you’re shooting for to win. One side of the craps puck says “On” and the other says “Off.” When it’s showing “Off,” you need a seven or 11 to win. When it’s “On,” you need to hit the number the puck is sitting on (the “point”) before a seven to win. Wow, quickest craps lesson, ever. Just ask your dealer for help.

We have no idea why the edges of craps pucks are made of rubber, unless they help prevent unintended pucklets.

The house edge for a Pass Line bet in craps is a mere 1.4%, making it one of the best bets in a casino.

Depending upon which way you turn the puck, it can read “On,” “No,” “Oz” or “Zo.” The Zo are an indigenous tribe in Myanmar, also known as Burma.

10. Bingo Dauber

Bingo players have the option of using machines to track their games, but lots of players still love to daub. Dauber manufacturers say purple is the most popular dauber color.

This is a new dauber, but the fun really starts when the sponge is saturated with inky goodness.

Some people make their own dauber ink. These people clearly have issues.

Much like with ChapStick, nobody has ever actually used up all the ink in a bingo dauber.

11. Craps Pyramid Bumper

OK, here’s our favorite close-up of the bunch. To ensure craps dice land randomly, there’s a portion of the craps table wall covered with pyramid-shaped bumpers. Some players claim they can influence the dice through practice and skill. The bumpers are intended to squash that possibility, real or imagined. This is why you’ll hear dealers and pit bosses insist, “Both dice need to hit the back wall.”

Some gamblers believe they can influence their roll by “setting” the dice, or putting them in a particular configuration before the throw. Players believe casino staff discourage the practice because dice-setting is a threat to the bottom line. It is, but not for the reason they think. Casinos don’t like dice-setting because it slows down the game. The quicker the pace of the game, the more money a casino makes.

We hope you’ve enjoyed our close-up tour of some common casino items. Maybe you’ll see them a little differently the next time you play!

Special thanks to our friends at the Gambler’s General Store for letting us photograph their stuff.