Casinos in the United States which generate more than $1,000,000 in annual gaming revenues are required to report certain currency transactions to assist the Financial Crimes Enforcement Network (FinCEN) of the Internal Revenue Service (IRS) in uncovering money laundering activities and other financial crimes (including terrorist financing).

1. Casino Slot Machine Payout
2. California Indian Casino Slot Machine Regulations

Although Title 31, also known as the Bank Secrecy Act, was originally focused on financial institutions, criminal use of banking services located within casinos created a need for additional regulations that were specific to casinos. Because large sums of currency are transacted through slot machines, gaming tables, automatic change machines, retail operations and the cage (banks), and with high frequency, the regulations were targeted at transactions in excess of $10,000. Casino regulation has been a topic of debate, prompting the United States Senate to have a hearing before the United States Congress in which Title 31 topics were discussed through testimony by industry experts such as Grant Eve, CPA and partner at Joseph Eve, Certified Public Accountants and Ernest Stevens Jr., Chairman of the National Indian Gaming Association.^[1]

Transaction reporting[edit]

Meet the necessary criteria. For some reason, though, all forms of casino games are currently banned. They at least have clear laws though, whereas things are decidedly murky in other countries. We’ve provide a detailed overview of European gambling laws, and also information on the laws in each of the following specific countries. DProxima, we don't have any regulations prohibiting photography / video and our policy is that it's ok on the slots but not on the tables. (In fact, we encourage video/photos on the slots) We do ask that people only video their machine and not wide shots that might include guests who may not want to be in the photo/video. Slot operators must have safeguards in place to protect player funds and customer’s cash must be kept separate from casino funds. This prevents casinos using customer money for their own upkeep and should slot sites go bust, then they will still be able to pay players their winnings.

Currency transactions that occur within a single Gaming Day (the normal 24-hour period that any casino uses for accounting and business reporting), whether the currency is paid into the casino, paid out, or exchanged (in the case of foreign currency exchanges), in excess of $10,000 requires the completion of a Currency Transaction Report (CTR, FinCEN Form 112) and must contain enough information to accurately identify the individual(s) transacting the currency.

For example, if a man walks into a casino and stops at the blackjack tables and buys into the game for $12,000 (using cash), a CTR must be completed by the casino and filed with the IRS. In this example, currency is paid into the casino in the form of cash and happened within the unique 24-hour Gaming Day of the casino.

Here is an example of a cash out transaction: the established Gaming Day of a certain casino begins at 1:00am and ends at 12:59am. At 6:30am, a woman takes $6,400 in slot machine tickets to the main cage of the casino and requests payment in all $20 bills. Later that day, at around 7:10pm, the same woman approaches another cash cage on the opposite side of the casino and exchanges $4,000 in blackjack chips for cash. Because $10,400 was paid out in cash to a single individual in a single Gaming Day, a CTR must be filed by the casino to report the Cash Out transaction, because it is above the $10,000 threshold.

Because multiple transactions are aggregated for the purpose of Title 31 reporting, casinos create tracking programs to identify large transactions and automatically aggregate them in real time to ensure that they are compliant with the regulations.

Suspicious activity[edit]

Many criminals, such as those interested in tax evasion and money laundering, have researched the Title 31 requirements and have created a number of strategies to avoid detection of their activities by circumventing the reporting requirements. When these activities are discovered, casino staff are required to file a Suspicious Activity Report (SAR, FinCEN Form 114) to report the suspicious activities. Because there are many types of suspicious activities, it is required that casino personnel receive Title 31 training to avoid penalty and remain compliant.

Two of the most popular strategies for circumventing CTR reporting are structuring and minimal gaming.

Structuring[edit]

Because the $10,000 per gaming day CTR threshold is part of the Bank Secrecy Act, a criminal may seek to evade being recorded on a CTR by breaking a transaction over $10,000 into multiple smaller transactions, which is known as structuring. Single and multiple currency transactions in excess of $10,000 (in a single Gaming Day) are reported to the IRS. To track multiple transactions, many casinos record transactions as low as $3,000 (and lower) to ensure that they remain compliant with the CTR requirements. Again, criminals (including those interested in tax evasion) may break up their transactions into several, smaller transactions to avoid detection.

For example, conducting three transactions of $4,000 is more than $10,000, which is the threshold of reporting a CTR. If the casinos did not track multiple transactions, the individual might be able to circumvent the reporting of their transactions. However, because most casinos track transactions of $4,000 (and lower), structuring this $12,000 transaction into three, smaller transactions would not prevent a CTR from being filed. And, while it may be possible to break up $12,000 into 20 individual transactions of $600 each, casino personnel also maintains awareness of this tactic and would likely detect the numerous trips to the cage to perform similar transactions.

Minimal gaming[edit]

Another type of suspicious activity is related to money laundering, where a casino patron may put large amounts of money in play, but gambles very little before cashing out.

For example, a bank robber steals $50,000 from a large bank. Most banks mark cash with exploding dye or sequential numbering of the large bills. To avoid being apprehended, the bank robber needs to exchange the stolen money for money that cannot be traced back to the robbery. In this situation, a bank robber may put $1,000 in $20 bills into a slot machine and spin twice before cashing out. Whether the slot machine pays the bank robber in coins or a slot ticket is irrelevant because the traceable money is in the machine and the bank robber will effectively receive 'clean' or 'laundered' money.

Both of these situations are suspicious, as defined by Title 31 regulations, and require a completed SAR by the casino, within a specified period of time.

Involvement of Agents[edit]

Two or more individuals handling the same currency bankroll are commonly referred to as 'agents' by the casino. An example of this would be individuals purchasing chips and dividing them amongst themselves. Agents cashing out chips or making currency transactions on behalf of one another are also popular examples of agent activity. Since agents handle the same bankroll, they essentially become entities and their transactions must be recorded together. All parties involved in agent activity must submit proper identification and complete the required IRS forms when their COMBINED transactions reach over $10,000 in a gaming day. While agent activity can sometimes occur with legitimate transactions (e.g. a husband cashing out his wife's slot vouchers so she can continue to play), agent activity is highly suspicious because it allows individuals to structure their transactions below the $10,000 to avoid being documented to the IRS.

Involvement of casino staff[edit]

It is illegal for an employee of the casino to assist a casino patron in circumventing the reporting requirements of Title 31. Such circumvention can include notifying patrons that they are nearing reporting thresholds, disclosing the time that the Gaming Day ends, and neglecting to report suspicious activity. A casino employee that has been found to have circumvented Title 31 can be assessed civil and criminal fines, in addition to incarceration.

References[edit]

1. ^United States Senate Committee on Indian Affairs (November 17, 2011). 'The Future of Internet Gaming: What's at stake for tribes?'. One Hundred Twelfth Congress First Session.

Casino Slot Machine Payout

International internet gambling law is a subject of immense complexity, because every nation has its own
take on the subject. Some parts of the world embrace online gambling while others do everything they
can to ban it entirely. On top of that, different jurisdictions within a single nation sometimes take radically
different approaches to internet gaming.

The United States is a great example of how complex gambling law can be within a single nation. Not only
are the federal laws poorly written and difficult to interpret, but individual states have their own laws as
well. In some states, online gambling is 100% legal and available to anyone inside state lines. In others, the
authorities are still trying to seize the assets of legitimate gambling sites.

Our goal with this part of our website is to take this massive subject and break it down for our readers.
We start this page by explaining some of the basics of online gambling legislation and regulation, which are useful to understand if you’re interested in
betting or gaming online. There is then some information on the gambling laws in various regions around the world. We’ve also included links to additional
pages where you can learn more about the legal status of both offline and online gambling in specific countries.

This page is divided into the following sections, to make it easy to find the specific region you may be looking for.

Online Gambling Legislation and Regulation: The Basics

The most important thing for you to understand about online gambling legislation and regulation is how it affects you. There are two key points to consider
in this respect.

1. It is rare for it to be explicitly illegal to USE an online gambling site
2. Licensed and regulated gambling sites are BY FAR the safest

The first point here is hopefully one that will put your mind at rest if you are worried about the legalities of gambling online, and the potential for
repercussions. The fact is that you are very unlikely to breaking the law simply by betting or gaming online. The vast majority of online gambling legislation
is target squarely at the companies that operate sites, and not the individuals who use them. Of course, laws do vary from one region to the next as we’ve
explained. It’s important to know your local laws do prohibit you from gambling online, which is precisely we’ve provided the relevant much information in
this section

In relation to the second point, most sites are licensed and regulated in at least one jurisdiction. To obtain the necessary license, they will have to meet
specific criteria as laid out by the licensing authority within the relevant jurisdiction. Operators will generally advertise details of their licensing, as it helps
to reassure potential customers that are legal and regulated. It basically lends some legitimacy to their operations. That’s what you’ll often see something
like the following on gambling websites.

You should know, however, that the actual legitimacy of licensing authorities varies quite significantly. The simple fact of the matter is some agencies are
much more stringent than others. For example, the state of Nevada puts any potential online poker site through the wringer before it issues a license to
operate. So a Nevada license has genuine sign validity. Other gambling authorities basically sell licenses to anyone with enough money, so these don’t
really mean much at all.

With that in mind, we decided to put together a comprehensive guide to licensing authorities around the world. We want you to know what it really means
when a site says it has a license to do business. You can use this information to assist in the search for a safe gambling site.

You should also understand why online gambling regulation is so important. Its primary purpose is to protect YOU, the consumers. You should be able to
gamble online with the confidence that you will be treated fairly not be exposed to dishonest or crooked practices. Thankfully, the established and
reputable licensing authorities ensure that you can do exactly that. They impose a strict code of conduct on the licensees, who have to adhere to the
necessary regulations if they are to maintain their licenses. That’s why properly licensed and regulated sites are the safest options.

For a more in-depth explanation of this subject, please see our page on how online gambling is regulated

Gambling Laws in North America

There are several countries in North America that have wildly different laws relating to gambling.
The United States is obviously the biggest country in this region, and as we’ve already mentioned
the laws here are very confusing. This is partly down to the fact that there are so many states,
each with their own attitude to gambling, but there is more to it than that. There is just a distinct
lack of clarity in so much of the relevant legislation. There is also much debate about whether
US laws actually apply to gambling sites that operate outside the region.

Things are not much better in Canada either. There is legislation in place that has been passed by
central government, but each individual province has the authority to regulate gambling in their
own regions. As with the US, the use of overseas sites is very much a grey area.

We’ve provided additional pages that explain the relevant legal situations in these two countries in much
more detail, and we’ve also covered some other countries in North America too.

Gambling Laws in Europe and the UK

Europe also has many countries with different approaches to the legality of online gambling.
Some countries outright ban it, while others have formally legalized it and put proper regulatory
frameworks in place. The United Kingdom is the best example of the latter. All forms of online
betting and gaming are completely legal, and very well regulated. Any site wishing to provide its
services to UK residents must meet requirements set out by the Gambling Commission. This
organization was established in 2005, replacing the existing Gaming Board.

There are other European countries with similar setups to the UK too. France, for example, has a
strict licensing process, but does allow overseas companies to accept French customers if they
meet the necessary criteria. For some reason, though, all forms of casino games are currently
banned. They at least have clear laws though, whereas things are decidedly murky in other countries.

We’ve provide a detailed overview of European gambling laws, and also information on the laws in each of the following specific countries.

Gambling Laws in Australia/Oceania

The laws for Australian gambling companies are very strict. They’re allowed to offer some gambling
services to Australian residents, but currently only traditional sports betting and lottery-style
games are permitted. Live sports betting is not allowed, and nor are casino games. There are no
laws that prevent Australians from using overseas sites though, as these fall outside the jurisdiction
of Australia’s government.

In New Zealand, unlike so many other regions, there is clear and precise legislation relating to
online gambling. The country passed a new act in 2003 to make sure that their laws were explicit and
easy to understand. Unusually, the act very plainly stated that the use of overseas sites is entirely
legal. Such sites are, however, banned from advertising in New Zealand.

You can read more about the country specific laws in this part of the world on the following pages.

Gambling Laws in Asia

There is very little consistency in the gambling laws throughout Asia. This is perhaps
not surprising, given the size of the continent and the number of different countries
it’s home to. Compiling an overview of Asian gambling laws would be a futile
exercise, but we have provided pages covering each of the following countries
separately.

Gambling Laws in South America

The general approach to gambling throughout South America is reasonably liberal.
There are restrictions on certain types of betting and gaming in some countries in the
region though. For example, casino games are prohibited in Brazil. Our guide to the
gambling laws in South America explains about these restrictions in more detail, and
also covers any relevant online gambling legislation.

California Indian Casino Slot Machine Regulations

Gambling Laws in Africa

Few countries in Africa have passed any kind of legislation relating on online gambling,
although South Africa is one notable exception. Land based gambling is another
matter though, with various forms fully legalized throughout the region. There are
casino venues, for example, in several countries. We’ve provided details on the various
gambling laws throughout Africa on the following page.

We recommend that you have at least passing familiarity with the legal climate with regards to gambling in
your location. A working knowledge of the law in your area may help to keep you safe from any legal trouble,
and will make it easier for you to find the sites that cater for customers in your part of the world.

Please be aware, though, that nothing contained in this part of GamblingSites.org should be considered as
actual legal advice. We’ve carried out extensive research and consulted experts when compiling all of
this information, but we are not qualified to provide legal advice. If you have any concerns about the
legalities of gambling online where you live, it would be best to speak to a licensed lawyer.