Must a casino identify suspicious customer chip redemptions at a cage for reporting on FinCEN Form 102 (SARC)?
Answer 16: A casino must implement procedures reasonably designed to assure the detection and proper reporting of suspicious transactions.47 Also, a casino shall file a report of each transaction in currency involving cash out of more than $10,000 in a gaming day in which it has obtained knowledge including the redemption of chips.48 A casino, which is not required by state or tribal regulations to maintain multiple currency transaction logs or currency transaction logs at the casino cage,49 nonetheless should develop an internal control50 based on a risk analysis to be able to identify chip redemptions that were paid with currency from the imprest drawer51 to a customer52 that involve potential suspicious transactions to assure ongoing BSA compliance. Such an internal control would aid such casinos in monitoring chip redemptions for “unknown” customers who previously purchased chips and then engaged in minimal or no gaming activity for purposes of suspicious activity reporting.53 As a
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- Must a casino identify suspicious customer chip redemptions at a cage for reporting on FinCEN Form 102 (SARC)?
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- Is the disclosure and attestation form sufficient to identify and resolve conflicts of interest?
