Casino Money Laundering Flashcards

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Questions and Answers

What is money laundering?

The disguising and concealing of illegal income in order to make it appear legitimate.

What is the Bank Secrecy Act (BSA)?

Legislation that requires U.S. financial institutions to collaborate with the U.S. government in cases of suspected money laundering and fraud.

What is an employee required to do when witnessing suspicious activity?

Report to Title 31 - File a SAR.

What does 'Culture of Compliance' mean?

Abiding by Internal Controls which comply with Policy and Procedures. Signup and view all the answers

What are the three phases of money laundering?

Placement, Layering, and Integration. Signup and view all the answers

Are civil and/or criminal penalties imposed for BSA violations?

True Signup and view all the answers

What does 'Cash In' mean?

Bills inserted into the player interfaces, currency exchanges, or when a guest provides cash to a casino. Signup and view all the answers

What does 'Cash Out' mean?

Transactions in which the casino provides cash to the guest. Signup and view all the answers

Who is considered an agent in a casino context?

A guest that conducts a transaction on behalf of another guest or organization. Signup and view all the answers

What is the Financial Crimes Enforcement Network (FinCEN)?

A bureau of the U.S. Department of the Treasury that collects and analyzes information about financial transactions. Signup and view all the answers

What is a gaming day?

The 24-hour period in which the casino keeps its books and records for business. Signup and view all the answers

What is a Monetary Instrument Log (MIL)?

A chronological record of monetary instruments indicating cash purchases of instruments valued between $3,000 and $10,000. Signup and view all the answers

What does it mean when you circumvent something?

Bypass, go around, or evade. Signup and view all the answers

What are Components for an Anti-Money Laundering Program?

CTR, SAR, Customer I.D. Program, OFAC. Signup and view all the answers

What does 'maintaining confidentiality' mean as it relates to Title 31?

Do not notify the subject of the SAR. Signup and view all the answers

What is a Multiple Transaction Log (MTL)?

A daily log that tracks and aggregates a Title 31 customer cash in/cash out. Signup and view all the answers

What is a Currency Transaction Report (CTR)?

Reports required for transactions in currency that exceed $10,000.01 in a single gaming day. Signup and view all the answers

What are examples of suspicious activity?

Transferring TITOs/Chips, large buy-ins then cashing out with little or no play, unusual questioning, and providing false information. Signup and view all the answers

What is aggregation in the context of casino transactions?

The act of totaling a guest's cash-in and cash-out transactions for the gaming day. Signup and view all the answers

What is a Suspicious Activity Report (SAR)?

A document that financial institutions must file with FinCEN following a suspected incident of money laundering or fraud. Signup and view all the answers

What does Know Your Customer (KYC) involve?

Verifying the identity of customers and assessing potential illegal intentions. Signup and view all the answers

Study Notes

Money Laundering

Concealing illegal income to make it appear legitimate.

Bank Secrecy Act (BSA)

Enacted in 1970 by U.S. Congress.
Mandates collaboration between financial institutions and the U.S. government to combat money laundering and fraud.
Aims to reduce the risk of financial institutions unknowingly aiding illicit activities.

Suspicious Activities Reporting

Employees must report suspicious activities by filing a Suspicious Activity Report (SAR) under Title 31.

Culture of Compliance

Involves adherence to internal controls, policies, and procedures that ensure regulatory compliance.

Phases of Money Laundering

Three distinct phases: Placement, Layering, and Integration.

Penalties for BSA Violations

Non-compliance can result in both civil and criminal penalties.

Cash In

Transactions where guests insert cash into player interfaces or currency exchanges at the casino.

Cash Out

Instances where the casino provides cash to guests, such as cashing checks or redeeming tickets.

Agent

A guest who conducts transactions on behalf of another individual or organization.

Financial Crimes Enforcement Network (FinCEN)

A U.S. Department of the Treasury bureau focused on analyzing financial transactions to combat money laundering and terrorism financing.

Gaming Day

Refers to the 24-hour period for which a casino maintains financial records for regulatory and accounting purposes.

Monetary Instrument Log (MIL)

A chronological record that tracks cash purchases of monetary instruments valued between $3,000 and $10,000.

Circumvent

To bypass or evade rules or regulations.

Anti-Money Laundering Program Components

Includes Currency Transaction Reports (CTR), Suspicious Activity Reports (SAR), Customer Identification Programs, and Office of Foreign Assets Control (OFAC) compliance.

Confidentiality and Title 31

Maintaining confidentiality involves not disclosing the existence of a SAR to the subject involved.

Multiple Transaction Log (MTL)

A daily log implemented to track and aggregate customer cash transactions for reporting purposes.

Currency Transaction Report (CTR)

Required when cash transactions exceed $10,000.01 in a single gaming day.

Examples of Suspicious Activity

Transactions involving suspicious transfers of chips, large buy-ins with minimal play, unusual inquiries, and the use of counterfeit currency.

Aggregation

Totaling guest cash-in and cash-out transactions to determine CTR reporting requirements.

Suspicious Activity Report (SAR)

A mandatory document for financial institutions to report suspected incidents of money laundering, fraud, or other suspicious activities.

Know Your Customer (KYC)

A process for businesses to verify customer identities and sources of funds to mitigate risks related to illegal activities.

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Description

Test your knowledge on key terms related to money laundering and financial regulations. This set of flashcards covers essential concepts like the Bank Secrecy Act and money laundering definitions. Perfect for students and professionals in finance and law enforcement.