Regulation 6A has been in effect in Nevada since 1985. State regulations have stipulated that casinos with annual gross gambling revenues of more than $10 million track cash transactions of more than $3,000, which are reported to the Gaming Control Board if they're "suspicious"; any cash transaction of more than $10,000 is automatically reported. The state has shared the reports with the U.S. Treasury, primarily the Internal Revenue Service. Regulation 6A was considered even more stringent, in some ways, than Title 31 of the federal Bank Secrecy Act; thus, Nevada casinos were exempt from Title 31, whereas casinos in all other states weren't.
Since 2001, the federal government has tried to crack down on money laundering linked to terrorists. The feds consider the so-called USA Patriot Act to be tougher than Reg. 6A and have been wanting to take over the regulation of cash transactions in Nevada. Nevada and Washington have been "negotiating" over the cash regulations for several years but, not surprisingly, the feds have prevailed.
The main difference between Reg. 6A and Title 31 is that the latter classifies casinos as financial institutions that are required to report cash transactions directly to FINCEN, the Treasury Department's Financial Crimes Enforcement Network; effective June 30, 2007, all casinos with $1 million in annual gross gambling revenues will be subject to federal reporting requirements, not just casinos with $10 million or more, as required by Nevada's Regulation 6A. This raises the number of Nevada casinos required to track cash transactions of $3,000 or more from 115 to 260.
Nothing else changes, except that the casinos now report directly to the U.S. Treasury Department (mainly FINCEN and the IRS), instead of to the state Gaming Control Board.
In fact, compliance life gets a little easier for the big casinos. Many of them already comply with Title 31 in other states. Also, federal law, unlike state law, doesn't prohibit certain transactions, such as changing $3,000 or more in smaller bills for larger bills, as Reg. 6A does.
And Gaming Control gets to free up agents' time from monitoring cash transactions to, for example, more frequent tax audits.
Finally, casinos with more than $1 million and less than $10 million in gross gambling revenues are mostly small slot operations, including bars and convenience stores, which see few if any cash transactions big enough to require reporting to the government.
So all in all, it's a net gain for Nevada. Nothing much changes for casinos, large or small. Nothing at all changes for gamblers. And state regulators have less responsibility.
