Once again, we turned to our trusted pseudonymous casino deep throat, Arnie Rothstein, to answer this question.
As of July 1, 2007, Nevada Regulation 6A is no longer law and has been abolished. The state of Nevada now refers to Title 31 (federal) as a means for the casinos to report cash transactions to the government.
Casinos are considered MSBs (Money Service Businesses) and must comply with FinCEN (Financial Crimes Enforcement Network) rules and regulations (which includes the Bank Secrecy Act). Title 31 has always been the rule for casinos in Arizona, California, Mississippi, New Jersey, etc., but up until two days ago, the Nevada casinos were exempt. No longer.
The casino cashier isn't required to request a Social Security number until the magic $10,000 threshold is breached (in other words, when the total of all cash transactions, "single or aggregated," exceeds $10,000 in a 24-hour period). If the casino patron is from a foreign country and shows a valid passport, no SS# is required, of course.
This is not only true when the customer puts cash into the casino, but also when the customer takes cash out of the casino. Cash-in includes: currency-for-currency exchanges; tournament or other player buy-ins; cash buy-ins at the table games; cash wagers; and any other cash-in transactions. Cash-out includes: check cashing; cashing out of gaming chips or tokens; jackpot payouts; currency-for-currency exchanges; tournament or other cash payouts; and any other cash-out transactions. (Cash-in transactions must be aggregated separately from cash-out transactions.)
Whenever transactions between a customer and the casino exceed $10,000 in cash-in or cash-out in a 24-hour gaming day, a Currency Transaction Report (CTR) must be filled out by the casino and filed with the Internal Revenue Service. In addition to the amount of the transactions, the CTR must also include: the customer's name, permanent address, and Social Security number.
The casino must verify your identity via a driver's license, passport, or other form of picture ID.
What about large cash transactions of less than $10,000 -- such as cashing in your $4,000 in chips?
In the past, Reg 6A allowed us to just write a description of the person making a large cash transaction of less than $10,000 (such as "white male, gray hair, about 50, 5'11, blue shirt"). This helped the employees in the pit keep tabs on certain players, then approach them to ask for ID when they exceeded the $10,000 cash threshold. But no longer.
Now, starting at $3,000, an MSB is required to record the transaction. According to Title 31, when recording a transaction of $3,000 to $10,000, the casino employee must: verify and record customer information, including ID; record transaction information, including the amount, date, and serial numbers if exchanging cash for travelers cheques; and retain the record for five years from the date of the transaction.
I should add that this is a gigantic nightmare for the casinos. All cage, slot, and pit employees have to be retrained. Records have to be kept for five years. And Suspicious Activity Reports are now much wider and grayer and start at $2,000. (The casino must also keep records on cash transactions of less than $3,000 if a casino employee deems a casino patron's behavior "suspicious" -- this deeming process is subject to the employee's personal interpretation.) The casinos also have to register as Money Service Businesses and start an Anti-Money Laundering compliance program (AML). In addition, it used to be that each pit was a discrete "watched area," but now it's the entire casino. So it's up to the pit staff to chase people all over the floor to see how much cash they might pull out of their pockets, then keep a tally of it and pass it on at the end of their shift. And those are just the highlights; a number of details add to the headaches.
