Part III: Business & Regulation · Banking, Chips & Financial Operations

Bank Secrecy Act (BSA)

Compliance & ReportingVERIFIED

(1) The Bank Secrecy Act (BSA), formally the Currency and Foreign Transactions Reporting Act of 1970, is the federal law that requires casinos with gross annual gaming revenue exceeding $1,000,000 to implement anti-money laundering (AML) programs and report certain financial transactions to FinCEN. The main BSA obligations for casinos include: (1) Currency Transaction Reports (CTRs) for cash transactions over $10,000 in a gaming day, (2) Suspicious Activity Reports (SARs) for suspicious transactions of $5,000 or more, (3) customer identification and due diligence, and (4) recordkeeping. A casino’s anti-money-laundering programme must include internal controls, independent testing, a designated compliance officer and training (31 CFR 1021.210). The BSA defines casinos as “financial institutions,” subjecting them to the same reporting obligations as banks for certain transactions. (2) The foundational US federal law enacted in 1970 that establishes the primary framework for anti-money laundering regulation. The BSA requires financial institutions, including casinos meeting gross annual gaming revenue (GGRA) thresholds, to maintain records, file reports, and implement programs designed to detect and prevent money laundering and the financing of terrorism. Casino compliance with the BSA is enforced by FinCEN and the IRS.

In practice

The BSA is codified at 31 U.S.C. Chapter 53 and enforced by FinCEN. Civil penalties are set by 31 U.S.C. 5321. Criminal penalties under 31 U.S.C. 5322 reach a fine of $250,000 and five years in prison, rising to $500,000 and ten years where the violation is part of a pattern of illegal activity or breaks another federal law.

One entry from the Casino Industry Glossary, 1,090 terms written for surveillance, compliance and operations professionals rather than for players. Definitions describe industry usage; where a term carries a regulatory meaning, verify against the instrument that governs your jurisdiction.