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#2083540 - 06/15/16 03:48 PM Consider this structuring?
Rancher Offline
Joined: Nov 2006
Posts: 74
Our customer has frequent casino transactions and also frequent cash deposits. The debits from the casino add up to be pretty close to the cash deposit amounts, so it appears that the casino is the source of the cash. Customer is averaging $50,000.00/month in casino debits and $50,000.00/month cash deposits. The cash deposits average between $4,000.00 to $6,000.00 total per day, none of the cash deposits have been CTR reportable. Gambling is not illegal, and none of the cash transactions are close to the CTR threshold, but due to the high amount of cash being deposited I'm wondering if this could be considered structuring?

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#2083556 - 06/15/16 05:07 PM Re: Consider this structuring? Rancher
NotDoneYet Offline
Gold Star
Joined: Jul 2010
Posts: 482
My casino playing customers would love to have those kind of odds.
Last edited by NotDoneYet; 06/15/16 05:08 PM.
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#2083557 - 06/15/16 05:09 PM Re: Consider this structuring? Rancher
NotDoneYet Offline
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Joined: Jul 2010
Posts: 482
My first thoughts are money laundering.

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#2083568 - 06/15/16 05:32 PM Re: Consider this structuring? Rancher
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,311
Pulling people out of the ditc...
I find it odd that he is breaking even month after month, I'd go more with money laundering than structuring as well...
Providing alternative truths since the invention of time

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#2083588 - 06/15/16 06:06 PM Re: Consider this structuring? Rancher
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
If you are registered under 314(b) you may want to check of the casino(s) are also registered under 314(b).
Regulations are a poor substitute for ethics.
Just sayin'

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#2083720 - 06/16/16 12:54 PM Re: Consider this structuring? Rancher
Compliance Risk Offline
Joined: Sep 2015
Posts: 69
It sounds to me like he is a big roller who goes gambling with about $5,000, about 10 times a month, and cashes out when he is down about $1,000 or up $1,000. Do you think the funds deposited are from a different source?

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#2096884 - 09/02/16 08:36 PM Re: Consider this structuring? Rancher
EB, CAMS Offline
100 Club
Joined: Mar 2009
Posts: 133
flyover country
We have seen similar activity to this with a couple of our casino frequenting customers. I'm trying to figure out what they are doing at the casino...taking out lots while they are there and then bringing almost all of it back in cash and depositing it to their account.

If its money laundering, please explain to me why or how.

It is actually possible for you and I to have different opinions and yet still live peaceably upon this planet.

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#2097047 - 09/06/16 06:46 PM Re: Consider this structuring? Rancher
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,565
The Country
Could be a form of money laundering.

Bobby goes to the casino with 5k in cash (think dirty money) and buys chips. Bobby then spends the next 2 hours puttering around the casino playing a few games here and there.

Bobby returns the chips and gets a check from the casino for the remaining 4.5k and deposits it at your bank.

The funds are now effectively laundered.
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2097471 - 09/08/16 03:13 PM Re: Consider this structuring? Rancher
fmissle Offline
Platinum Poster
Joined: Jul 2007
Posts: 955
Pac NW
But I think in the scenario OP posted, they can see the debits from the Casino which offset the cash he receives.

So he goes to the casino, gets $5000 (check?) and then later deposits $5,000. Doesn't seem like there's laundering there, but maybe I'm missing something or entirely misunderstanding.

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#2097473 - 09/08/16 03:17 PM Re: Consider this structuring? Rancher
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
In Rock Chucker's scenario, surely the casino's AML systems would catch this pattern? Chips purchased with cash, and checks issued for nearly that amount?

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#2097499 - 09/08/16 04:38 PM Re: Consider this structuring? Rancher
edAudit Offline
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Joined: Jul 2008
Posts: 4,714
You are here
Chips could be purchased at the table with no id. I do not know the limit.
Opinions can be considered as coming from anywhere but my employer.


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