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

53. Suspicious Activity Report (SAR)

Financial Transactions

A Suspicious Activity Report (SAR), filed on FinCEN Form 111, is the confidential report that casinos must submit when they know, suspect, or have reason to suspect that a transaction or pattern of transactions aggregating at least $5,000 involves funds derived from illegal activity, is designed to evade BSA reporting requirements (structuring), has no apparent lawful purpose, or involves use of the casino to facilitate criminal activity. SARs must be filed within 30 calendar days of initial detection (extendable to 60 days if the suspect cannot be identified). It is illegal to notify any person involved that a SAR has been filed. Casinos are not required to prove criminal activity — only that the transaction is suspicious.

In practice

SAR confidentiality is absolute — “tipping off” a subject that a SAR has been filed is a federal crime. Casinos have protection from civil liability when filing SARs in good faith.

One entry from the Casino Industry Glossary — 1,157 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.