Are horse racetracks that offer pari-mutuel or other forms of wagering only on races held at the track considered casinos for purposes of the BSA?
Answer 7: FinCEN does not view a horse racetrack that offers pari-mutuel or other forms of wagering only on races held at the track as a casino for purposes of the BSA. We believe that, under these circumstances, wagering is integral to hosting the race itself. Horse racing as an industry poses “different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.”17 Section B: 31 C.F.R. 103.22 Currency Transaction Reporting Requirements18 Question 8: Is a casino required to provide identification information on customers who have conducted reportable multiple currency transactions that were summarized through “after the fact aggregation?” Answer 8: The process of checking internal casino computer information, rating cards, general ledgers, and other books and records after the end of the gaming day to find reportable currency transactions is sometimes referred to as “after the fact aggregation.” After the fact aggregation of c
Answer 7: FinCEN does not view a horse racetrack that offers pari-mutuel or other forms of wagering only on races held at the track as a casino for purposes of the BSA. We believe that, under these circumstances, wagering is integral to hosting the race itself. Horse racing as an industry poses “different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.”17 Section B: 31 C.F.R. 103.22 Currency Transaction Reporting Requirements18 Question 8: Is a casino required to provide identification information on customers who have conducted reportable multiple currency transactions that were summarized through “after the fact aggregation?” Answer 8: The process of checking internal casino computer information, rating cards, general ledgers, and other books and records after the end of the gaming day to find reportable currency transactions is sometimes referred to as “after the fact aggregation.” After the fact aggregation of c
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