CTR Basics
What does CTR stand for?
what is Currency Transaction Report
What is structuring?
what is breaking up transactions to avoid reporting requirements?
what might it mean if a guest insists on using multiple ID's
possible structuring or hiding identity
At what amount must we obtain valid ID
when cash in/out is at 10k or you have valid reason to collect due to suspicious behavior or you have reason to collect due to them being very close to threshold and believe you will not get it later.
what federal agency enforces title 31 rules
FinCEN (financial crimes enforcement network)
At what dollar amount must a CTR be filed?
What is $10,000 or more in one gaming day
Is structuring illegal even if the money is legal?
what could be suspicious about a guest refusing to sign required forms
may be trying to avoid detection or reporting
what forms of ID are acceptable for Title 31 purposes
government issued photo ID's like drivers license passports etc
what is the main goal of title 31
to prevent money laundering
Can multiple small transactions add up to require a CTR?
What is yes, if the total is over $10,000 in a single business day
Give one sign someone might be structuring
repeatedly cashing out just under 10k
multiple small transactions instead of one large one
minimal play with large transfers
a guest cashes out 9900 in chips, then comes back an hour later with more, what might this indicate
potential structuring
false
how long must title 31 records be kept
5 years
Who is responsible for filing CTR in a casino?
what is title 31 compliance department
what is used to structure?
what is chips, tickets, cash
what does it mean if a guest asks a cashier "what amount gets reported?"
RED FLAG, they may be trying to avoid title 31 thresholds
what info must be collected with ID
Name, address, DOB, SSN or TIN
who is responsible for following title 31
EVERYONE!
what is the time frame in which a CTR must be filed once the transaction is identified
15 calendar days from the date of transaction
what must you do if you suspect structuring?
report to your supervisor and file a SAR
name one red flag related to the use of third parties in cage transactions
someone conducting transactions on behalf of another person without explanation or trying to use another persons ID
When a SSN is not available due to guest being foreign, what do you collect?
ID proof (matricula, foreign passport, green card etc)
what are the consequences for a casino that fails to comply with title 31 regulations
heavy fines, loss of gaming license, federal investigation