Is a card club required to maintain and retain records of all currency transactions by customers pertaining to backline betting for purposes of currency transaction reporting?
Answer 11: Yes. The BSA requires card clubs to maintain and to retain the original or a microfilm copy of records of all currency transactions by customers, including without limitation, records in the form of currency transaction logs and multiple currency transaction logs.33 This requirement applies to card clubs34 that offer the practice of backline betting. Backline betting occurs when a customer, who is standing behind a seated player, places a bet or wager on the betting circle for a specific hand on which a seated player also is wagering. The extra players that stand behind each seat position are known as “backline betters.” Although backline betting makes it difficult to track customer wagers at the gaming table, a card club must have a procedure in place to identify such transactions for purposes of filing a FinCEN Form 103 (CTRC).35 A card club must have procedures for using all available information to determine and verify, when required, the name, address, social security o
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