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 BSA’s four pillars of compliance for casinos are: (1) Currency Transaction Reports (CTRs) for cash transactions exceeding $10,000, (2) Suspicious Activity Reports (SARs) for suspicious transactions of $5,000 or more, (3) customer identification and due diligence procedures, and (4) comprehensive recordkeeping requirements. 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. Violations can result in civil penalties up to the greater of the transaction amount or $250,000, and criminal penalties up to $500,000 and 10 years imprisonment.

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.