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#2202759 - 01/11/19 06:54 PM Banking a Casino
fudoshin314 Offline
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Joined: Sep 2017
Posts: 38
Anyone bank a casino and would be willing to share what they have in their program/what they do to monitor their transactions, etc. Thank you.

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BSA/AML/CIP/OFAC Forum
#2203332 - 01/17/19 08:59 PM Re: Banking a Casino fudoshin314
JennKK2 Offline
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is the casino considered its own sovereign nation?
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#2203343 - 01/17/19 09:42 PM Re: Banking a Casino fudoshin314
osucpa Offline
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Joined: May 2011
Posts: 1,402
I think you are talking about 2 different issues here. Are you talking about a Casino ran by an Indian Tribe on their land or are you talking about a casino such as the Flamingo in Las Vegas?

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#2203773 - 01/23/19 10:13 PM Re: Banking a Casino fudoshin314
fudoshin314 Offline
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Not on a reservation/run by an indian tribe.

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#2203785 - 01/23/19 10:45 PM Re: Banking a Casino fudoshin314
raitchjay Online
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I'm not a BSA guy, so please feel free to enlighten me, but what difference from a BSA standpoint would it make whether a casino is run by Indians or a privately owned company?
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#2203875 - 01/24/19 06:27 PM Re: Banking a Casino fudoshin314
JennKK2 Offline
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we bank a casino which is Indian owned and located on a reservation. we transact their bulk currency shipments, a BSA area; they frequently issue checks over $3,000.00, a transaction that would appear on our Proof currency reports, a BSA review item; and have exempted them from CTR filing, another BSA area.
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#2203876 - 01/24/19 06:33 PM Re: Banking a Casino fudoshin314
raitchjay Online
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I guess my question is.....do Indian run casinos get BSA breaks that a non-Indian casino would not? And if so....why?
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#2203934 - 01/24/19 09:38 PM Re: Banking a Casino fudoshin314
MNCompliance Online
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I believe the big differences is that because Native American Reservations are considered a sovereign nations you can exempt that as a Phase I customer for CTR reporting purposes.

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#2203942 - 01/24/19 09:56 PM Re: Banking a Casino fudoshin314
fudoshin314 Offline
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Joined: Sep 2017
Posts: 38
@JennKK2 - aside from filing CTRs, how do you monitor their activity via your AML software?

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#2203946 - 01/24/19 09:59 PM Re: Banking a Casino MNCompliance
raitchjay Online
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Originally Posted By MNCompliance
I believe the big differences is that because Native American Reservations are considered a sovereign nations you can exempt that as a Phase I customer for CTR reporting purposes.


Thank you MNCompliance....that's what i was wondering about.
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#2204011 - 01/25/19 05:01 PM Re: Banking a Casino fudoshin314
JennKK2 Offline
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@fudoshin314
the only time we are filing CTRs is when "Joe Blow" brings in a check from the casino to cash with us. the casino is a sovereign nation therefore we don't file CTRs on "them". we document their bulk currency shipments, we annually receive their certification as a sovereign nation, and review daily our currency reports which are triggered at any $3,000.00 cash transaction. they do utilize the RDC service and so I had them on my high risk monitoring list for a few quarters to ensure the deposits were "problem free". We have had this relationship for many years but I would have expected when we did acquire their accounts, they were met with and a review of their BSA policy was conducted. Casinos have their own type of CTR form so ensuring they have a BSA AML program may provide you with additional assurances.
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#2204027 - 01/25/19 05:30 PM Re: Banking a Casino fudoshin314
fudoshin314 Offline
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@JennKK2 Thank you!

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