Can you provide a list of all the major casinos' “day”? Boyd, Caesars, etc. If this has been done somewhere, I’m having trouble finding it.
A casino's "gaming day," according to FinCEN, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury, is defined as "the normal business day of a casino or card club," in other words, the 24-hour period by which a casino keeps its records for business, accounting, and tax purposes. A single gaming day, whether it runs from 12:01 a.m. to midnight, 6:01 a.m. to 6 a.m., or 10:01 p.m. to 10 p.m., "facilitates the aggregation of transactions for purposes of currency-transaction reporting."
Now, why would a player want to know this information?
Federal law requires financial institutions, including casinos, to report currency (cash and/or coin) transactions of more than $10,000 in a single 24-hour period -- i.e., the gaming "day." This includes multiple currency transactions that, in the aggregate, add up to $10,001 or more in a single day.
Ergo, anyone who wants to know what a casino's gaming day is could be contemplating a financial crime known as "structuring," or "smurfing," which means divvying up what would otherwise be a financial transaction, usually more than $10,000 in a 24-hour period, that would require a CTR in order to avoid scrutiny by regulators and/or law enforcement.
Example: At 7 p.m., a slot player cashes $6,000 worth of TITO vouchers at the cage. Then at 1 a.m., she cashes another $2,500. Finally, at 5 p.m. the next evening, she cashes $4,000. In the aggregate, she enacts cash transactions worth $12,500 within a 24-hour period, so the casino, keeping track of the cash, is required to fill out and submit a CTR to FinCEN.
Now, say the casino day is 7:01 p.m. to 7 p.m. and say the slot player cashed the final $4,000 at 7:30 p.m. instead of 5 p.m. Was she structuring? Maybe yes, maybe no. But if the casino suspects that she was, it now files an SAR or Suspicious Activity Report; if FinCEN determines that something fishy was going on, investigators might look more deeply into the financial transactions of the slot player.
Which is why the whole subject of the casino gaming day is shrouded in mystery and intrigue.
In fact, read the following.
"Dear Valued Guest,
"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. 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's the text from the standard card that casino employees are instructed to give to guests who inquire about the gaming day or the information required from patrons for the Currency Transaction Report.
The gaming day is probably the most closely guarded secret in the casino industry. Many of the employees aren't even sure about the times. Employees who do know the gaming-day cycle can be fired on the spot if they disclose it to anyone from the public. Casino employees are even trained never to reveal the $10,000 trigger when gathering info. If someone asks about it, that also leads to handing the guest the explanatory card or answering with similar verbiage. Of course, it's a pretty well-known amount, but transactions that go over it in a day are reported on the CTRs.
All in all, compiling a list of gaming days for any casino, let alone all the major casinos, is a tall task indeed. We're sure some savvy players out there possess this information and are, in various ways, able to circumvent CTRs and SARs, but it's certainly not anything we can tackle in a capacity other than explaining, as we have, the underlying rules and regulations.
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