Is a tribal gaming establishment that offers only bingo and related games considered a casino for purposes of the BSA?
Answer 2: No. FinCEN has the authority under the BSA to define as “casinos” tribal gaming establishments that offer only bingo and related games. Nevertheless, in addressing the treatment of tribal gaming under the BSA, we have indicated that “activities such as bingo . . . are not generally offered in casino-like settings and may create different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.”6 FinCEN does not view tribal gaming establishments that offer only traditional bingo (i.e., not contained in electronic gaming devices) and related games in non-casino settings as satisfying the definition of “casino” for purposes of the BSA. However, a tribal gaming establishment that offers both bingo and slot machines or table games, for example, would satisfy the definition of “casino,” if gross annual gaming revenue exceeds $1 million. All gaming activity must go into the calculation of gross annual gaming revenue, incl
Answer 2: No. FinCEN has the authority under the BSA to define as “casinos” tribal gaming establishments that offer only bingo and related games. Nevertheless, in addressing the treatment of tribal gaming under the BSA, we have indicated that “activities such as bingo . . . are not generally offered in casino-like settings and may create different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.”6 FinCEN does not view tribal gaming establishments that offer only traditional bingo (i.e., not contained in electronic gaming devices) and related games in non-casino settings as satisfying the definition of “casino” for purposes of the BSA. However, a tribal gaming establishment that offers both bingo and slot machines or table games, for example, would satisfy the definition of “casino,” if gross annual gaming revenue exceeds $1 million. All gaming activity must go into the calculation of gross annual gaming revenue, incl
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