How can a casino complete suspicious activity reporting (“SAR”) for “unknown” subjects?
Answer 15: Since a casino or a card club is prohibited from disclosing to a customer involved in a suspicious activity that it filed a FinCEN Form 102, Suspicious Activity Report by Casinos and Card Clubs (“SARC”), FinCEN advises using internal records that contain verified customer identification information when filing this form. Such records may include credit, deposit, or check cashing account records or any filed FinCEN Form 103 (CTRC), FinCEN Form 103-N, Currency Transaction Report by Casinos – Nevada, IRS Form W-2G, Certain Gambling Winnings, or IRS Form W-9, Request for Taxpayer Identification Number and Certification. If the above records or reports do not exist or if additional customer identification information is needed to complete the form, FinCEN advises casinos and card clubs to use any other records that may be on file which contain verified identification such as a driver’s license, military or military dependent identification cards, passport, non-resident alien regi
