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