Consider this structuring?

Posted By: Rancher

Consider this structuring? - 06/15/16 03:48 PM

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?
Posted By: NotDoneYet

Re: Consider this structuring? - 06/15/16 05:07 PM

My casino playing customers would love to have those kind of odds.
Posted By: NotDoneYet

Re: Consider this structuring? - 06/15/16 05:09 PM

My first thoughts are money laundering.
Posted By: HappyGilmore

Re: Consider this structuring? - 06/15/16 05:32 PM

I find it odd that he is breaking even month after month, I'd go more with money laundering than structuring as well...
Posted By: Princess Romeo

Re: Consider this structuring? - 06/15/16 06:06 PM

If you are registered under 314(b) you may want to check of the casino(s) are also registered under 314(b).
Posted By: Compliance Risk

Re: Consider this structuring? - 06/16/16 12:54 PM

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?
Posted By: EB, CAMS

Re: Consider this structuring? - 09/02/16 08:36 PM

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.

Posted By: RockChucker, CAMS

Re: Consider this structuring? - 09/06/16 06:46 PM

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.
Posted By: fmissle

Re: Consider this structuring? - 09/08/16 03:13 PM

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.
Posted By: Daisy Doodle

Re: Consider this structuring? - 09/08/16 03:17 PM

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?
Posted By: edAudit

Re: Consider this structuring? - 09/08/16 04:38 PM

Chips could be purchased at the table with no id. I do not know the limit.