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?
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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