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

Title 31

Compliance & ReportingVERIFIED

(1) Title 31 refers to the regulations at 31 CFR Chapter X that implement the Bank Secrecy Act and are enforced by FinCEN. In the casino industry, “Title 31” is commonly used as shorthand for the entire BSA/AML compliance framework applicable to gaming operations. Title 31 requirements include establishing a written AML program with internal controls, designating a compliance officer, conducting employee training, performing independent testing, maintaining transaction records for five years, and filing CTRs and SARs as required. Casino employees often refer to “Title 31 training” as the mandatory education on BSA compliance responsibilities. (2) The section of the US Code of Federal Regulations implementing the Bank Secrecy Act that specifically governs casino recordkeeping and reporting requirements. Casinos with gross annual gaming revenue (GGRA) exceeding $1,000,000 must comply with Title 31 requirements, including filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), maintaining an AML program, and adhering to specific recordkeeping standards. Casinos with GGRA below this threshold fall under Title 26 requirements instead.

In practice

The term “Title 31” is used more frequently in gaming than in banking, where “BSA” is the more common reference. Title 31 training is required for all casino employees with BSA-related responsibilities.

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.