Money Laundering

  FinCEN issued an advisory on apparent structuring by casino patrons and personnel. Structuring occurs when transactions are broken up for the purpose of evading Bank Secrecy Act (BSA) reporting or recordkeeping requirements. FinCEN said in a press release that it recently received information from law enforcement and regulatory authorities that raised concerns about the current level of compliance with obligations to guard against structuring. The BSA requires casinos to implement a compliance program, file reports and maintain certain records. Each casino’s program must be reasonably designed to manage the risk of illicit activity and ensure BSA compliance, including an obligation to detect and report evidence of structuring violations on FinCEN Form 102, Suspicious Activity Report by Casinos and Card Clubs.

More information is available at fincen.gov. FinCEN Advisory FIN- 2009-A003, Structuring by Casino Patrons and Personnel, is available at tinyurl.com/n3m2gs.