We have a customer who is operating a game room and falls under the definition of "Card Club" according to the BSA regulation. This customer is approaching the $1,000,000 in annual gross gaming revenue. If this customer does more than $1,000,000 in gross gaming revenue, is he an MSB? Or just a non-bank financial institution?

Will he become an MSB, (but not a check cashing business), and will he have to register as an MSB?

If he accepts traveler's checks as payment for the gaming, does he have to register as an MSB? Does the amount of the traveler's check matter? The biggest we see is $500 in a day for one customer.

I need to provide guidance to this customer as he is considering expanding his business and will reach the gross gaming revenue limit soon. And we will need to consider if we will keep his account if he becomes an MSB.

"I need to provide guidance to this customer as he is considering expanding his business and will reach the gross gaming revenue limit soon."

That is a very dangerous statement. Your customer needs to go to thier CPA and attorney and figure this out for themselves. The bank should not be giving customers legal advice.

He will not be an MSB, but will be considered a financial institution and subjected to all parts of the regulation that applies to financial institutions and more specifically casinos.

We don't provide guidance to our MSBs or suspected MSBs. We have them contact their accountant or attorney, and we also provide them with the FinCen phone number and web address.

If something happens later, I don't want them to say that they did what we told them to do and we should be held accountable.

Sorry this is an old post - but it's somewhat relevant.


Besides EDD, what else is required to gather from a Card Club?

I'm guessing I need to get their gross gaming revenue numbers to determine if I have to ask for their AML programs, etc ...