Is a casino required to use customer currency transaction information contained in the casinos slot monitoring system for purposes of BSA currency transaction reporting?
Answer 9: For purpose of the BSA, FinCEN does not view customer “coin-in” and “coin-out”23 transactions at a slot machine or video lottery terminal to be reportable as currency transactions because they can represent so-called “recycled” coin transactions (i.e., casino customers typically engaging in transactions deriving from the same coins just won at electronic gaming devices). If a casino were to use “coin-in” and “coin-out” information in its slot monitoring system, it would distort and result in incorrect reporting of currency transactions. However, when a casino has knowledge of customer “paper money” transactions for slot club accountholders identified through its slot monitoring system, it must aggregate these with other types of “cash in” transactions of which the casino has knowledge and which are recorded on a casino’s books and records to determine whether the currency transactions exceed $10,000 for a customer in a gaming day.24 When a casino has knowledge of multiple cur
Answer 9: For purpose of the BSA, FinCEN does not view customer “coin-in” and “coin-out”23 transactions at a slot machine or video lottery terminal to be reportable as currency transactions because they can represent so-called “recycled” coin transactions (i.e., casino customers typically engaging in transactions deriving from the same coins just won at electronic gaming devices). If a casino were to use “coin-in” and “coin-out” information in its slot monitoring system, it would distort and result in incorrect reporting of currency transactions. However, when a casino has knowledge of customer “paper money” transactions for slot club accountholders identified through its slot monitoring system, it must aggregate these with other types of “cash in” transactions of which the casino has knowledge and which are recorded on a casino’s books and records to determine whether the currency transactions exceed $10,000 for a customer in a gaming day.24 When a casino has knowledge of multiple cur
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