Part III: Business & Regulation · Gaming Regulation & Compliance

Suspicious Activity Report (SAR) / Suspicious Transaction Report (STR)

AML/CFT

A confidential report filed with the relevant Financial Intelligence Unit (FinCEN in the US, FIU in other jurisdictions) when a casino knows, suspects, or has reason to suspect that a transaction or pattern of activity involves funds derived from illegal activity, is designed to evade reporting requirements, has no apparent lawful purpose, or involves use of the casino to facilitate criminal activity. In the US, SARs must be filed for transactions involving $5,000 or more. Casinos must file SARs within 30 calendar days of initial detection (up to 60 days if the suspect cannot be immediately identified). Notification to the customer that a SAR has been filed is strictly prohibited (“tipping off”).

In practice

In Canada and many other jurisdictions, the term STR (Suspicious Transaction Report) is used. The US uses SAR. Macau requires reporting to DICJ.

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.