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

66. Bank Secrecy Act (BSA)

Compliance & Reporting

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.

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 — 1,157 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.