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Question of the Day - 29 September 2022

Q:

Table minimums have increased dramatically over the past two years. In order to play craps at the $15 or $25 minimums with a relatively low house edge, I needed to increase my buy-in to $1,000- $2,000. On a recent trip at a $25 table at Park MGM after several good shooters, I had nearly $6,000 in the rail including. At the cage, I asked how much I could change without needing to provide ID and she was indefinite, so I cashed in $4,000 and saved the remainder for later. I asked her pointedly if $10,000 was okay, and she said no, but didn't elaborate. What is the casino policy and the law on what can be cashed in at the cage without mandating paperwork?

A:

We've answered any number of variations on this theme over the years and we can say with some confidence that the casino policy on amounts that can be cashed at the cage without triggering financial-reporting paperwork, in general, isn't public information. It's simply something that the casinos don't relish publicizing. 

Here is the text from the standard card that casino employees are instructed to give to guests who inquire about information required from patrons for the Currency Transaction Report.

"We would like to take this opportunity to inform you of Title 31 of the Federal Bank Secrecy Act administered by the United States Department of Treasury. Under this Act, all casinos are required to report certain cash transactions on a Currency Transaction Report (CTR). In order to fully complete this report, our casino is required to obtain the following: government issued photo identification, your legal name, permanent address, date of birth and your social security number. Please note that our casino employees are strictly prohibited from discussing information regarding Title 31. Your cooperation with our casino in meeting these federal requirements is greatly appreciated."

That said, the law is clear about reporting cash transactions, which is required for amounts of $10,001 or more. Which is why your cashier told you that $10,000 is not okay when you asked if you could change $10K without providing ID. Even so, casino employees are trained never to reveal the $10,000 amount.

There's also the Suspicious Activity Report, which is required to be filed if the casino knows or suspects that a patron's funds are derived from some illegal activity, or if the patron is actively attempting to hide assets from an illegal activity, or circumvent federal law by avoiding reporting requirements. There's a laundry list of suspicious activities on the Financial Crimes Enforcement Network (FinCEN) page "Red Flags for Casinos and Card Clubs," in case you're interested.

This is a lesser-known threshold, though it's generally believed to be (and the lowest number on the FinCEN page is) $3,000. Still, a casino can file an SAR for any amount if it has any suspicions that something fishy going on with cash or chips, especially if it suspects a patron is attempting to "structure" cash transactions to avoid reporting requirements. This includes, but is certainly not limited to, customers playing many different games, buying and cashing in chips all over the place, and/or taking markers and cashing out for multiple smaller amounts.  

It's a huge a tracking problem for large casinos, so they record many single transactions between $3,000 and $10,000. Obviously, this doesn't always happen, as it sounds like it didn't happen to you. But the casino would be within its rights to make it happen for transactions in the low four figures.

 

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Comments

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  • Dave_Miller_DJTB Sep-29-2022
    Asking…
    The original questioner asked, and then cashed in only $4000. That alone is suspicious and should have triggered a suspicious activity report.

  • Derick Sep-29-2022
    cashout
    Wife and I playing videopoker had numerous wins and we would combine our tickets of the quarter 3 line games and cash in at cashier. After a while I assumed we were over $10000 cashing in tickets and had to fill out paperwork. Not difficult for casino to see off our play we were legit in th cashouts so i guess its a comuter system that automates it to be done. Would also say that the machine to cash your tickets is linked too. 

  • Lucky Sep-29-2022
    Cash out paperwork
    The correct answer is at $10,001, they MUST get the id, SS#, etc., for the transaction.  It is optional for lessor amounts, and the casino can ask for all that informatoin for any transaction at the cage.  Depends on the policy of that casino.

  • Tabbycat Sep-29-2022
    Better Correct than Lucky
    @Lucky “Lessor” amounts?  Who brought up leasing?  Not sure what “informatoin” is but pretty sure it’s not a synonym for “correct.”

  • Kevin Rough Sep-29-2022
    A report should have been filed
    I would be surprised if a report wasn't filed when he asked and then didn't cash in all of his chips.  That alone was questionable.
    
    But if you aren't doing anything illegal, you have nothing to worry about.

  • jay Sep-29-2022
    If you ask
    If you ask, you are probably deemed suspicious and they will make you fill in paperwork for that .50c chit you got on your last blackjack. 
    
    I would recommend cashing in random amounts like $3225 vs $3000 or even numbers of any sorts. You can also watch for shift changes at the cages before getting back in line.

  • jay Sep-29-2022
    The perfect divorce 
    I had once read about the perfect divorce where the exiting partner would go to the casino after work, exchange $1000 for chips, play one hand, get a buddy to cash out and then bury the cash in a coffee can. This was repeated daily including taking lines of credit on the house, leans on the car title and driving the family into apparent sizeable debt. The person had video evidence of them entering the casino, playing but none of the cash out.
    
    When it came time to do the divorce  - they declare financial ruin and pass half the debt onto the other spouse. 
    
    I am not sure if this could be pulled off in reality but the QOD cash out question did peak my interest. At $1000/day it might take you years to burn through savings and home equity so you would want it to be a much higher withdrawal. 

  • rokgpsman Sep-29-2022
    $10k reporting
    The law to report transactions that are more than $10,000 isn't just for casinos, it applies to any business or individual in the United States that receives cash money for something. Banks, jewelry stores, auto and boat dealerships, real estate agents, lawyers, etc all have to comply with reporting the transaction to the government (IRS). It's purpose is finding out about criminal activity that the cash came from. The regulation also requires any suspicious activity trying to avoid the law to be reported. And the staff at the business is instructed to not give very much information about the reporting procedures.

  • Raymond Sep-29-2022
    SAR
    If you make a big deal out of pocketing some of your chips, it will show up on video if the casino is suspicious and checks your movements.  I'm enough of a "middle roller" that it has rarely been an issue, as they probably don't care one way or the other if you're cashing out for $1,000.  But after an unbelievable roll at my favorite local place last December, they asked some questions--calling the pit I'd just left, etc.  I waited patiently; after all, they were just doing their job and not hassling me.  I've been told that sometimes the reason they file a SAR is because someone raises heck over a delay in payment.
    
    As I tell people who get upset, "They'd rather not have to file a report, but if you give them enough grief, they'll be happy to oblige you."

  • Roy Furukawa Sep-29-2022
    Structuring
    People rarely know this, but if they continually deposit just under the $10k threshold to avoid the paperwork, you get caught under the structuring rule. You can do it once or maybe even twice and you're probably okay, but if you go to banks or casinos and do it a few times or more you might get caught under that rule because you're showing that you're trying to avoid the reporting.