I tried searching for prior post on this topic, but I couldn't get any returned results (I am sure this has been a prior subject).

How do you view individuals that are frequent gamblers? I have a large customer base that will use 80% of their account for gambling. Sometimes you will see typical consumer activity (rent, groceries, cell phone bills, etc) and others will have strictly gambling. I've seen $80k in cash withdrawals and $60k - $100k in deposits within a 3-4 month review period. Sometimes there will be ACH transactions to the casino and a lot of ATM usage at or near the casino. The activity can appear micro structured at times, but it's hard to tell since they literally almost live at the casino and make multiple deposits and withdrawals a day.

Do you treat those that use cash and minimal ACH differently than those that solely rely on cash? Please explain your philosophy.

Do you recommend account closure or keeping them open?

http://www.irs.gov/uac/Gambling-Winnings-Are-Always-Taxable-Income

Gambling Winnings Are Always Taxable Income


I would think that it is not illegal.

Suppose that you identify an account that shows transaction patterns like the ones that "CFR31 Ch X" has described. After some due diligence in the form of conversations with the customer you determine that the customer is heavy into gambling, but apparently only at legal casinos. I don't see a SAR in that, unless the pattern of transactions also suggests structuring. That's going to be pretty difficult to detect since so much casino activity is non-cash.