FFIEC BSA/AML General Definitions

But the definition kept getting redefined to broaden its scope. Eventually the failure to fill out one of the BSA reports became, by legal definition, money laundering also. But the expansion of law didn't stop there. Since some people attempted to evade the $10,000 threshold in the BSA reporting requirements, legislation was imposed that made "smurfing" or "structuring" a crime also. To The specific BSA regulations that govern the casino/card club industry are codified at 31 CFR §1021. The reason why casinos and card clubs are subject to Title 31 compliance is that casinos and card clubs provide certain banking services for large sums of money that are advantageous to criminals looking to launder money or carry out other financial crimes; such services include: deposit Hawaiian Gardens Casino: On July 15, 2016, FinCEN imposed a $2.8 million civil penalty against the casino for allegedly repeatedly violating its BSA requirements. FinCEN attributed these failures to the club’s lack of a compliance culture, emphasizing that: (1) its leadership failed to meet as required by its charter; (2) its leadership failed to review and approve its risk assessment; and REMINDER: As of April 1, 2013, financial institutions must use the new FinCEN reports, which are available only electronically through the BSA E-Filing System.FinCEN is no longer accepting legacy reports. For more information, click here. Chapter X List for Casinos/Card Clubs (Updated November 18, 2010); Chapter X Main Page The BSA officer needs to be at the ground level of these discussions in order to assess the money laundering risks and implement controls. If not, it could result in taking on unnecessary risk. Compliance personnel must also have access to a variety of casino information systems beyond the multiple transaction log or negotiable instrument log definition of casino for purposes of the BSA. In general, the term refers to horse racetracks that may be authorized under state law to engage in or offer a variety of collateral gaming operations, including slot machines, video lottery terminals, video poker or card clubs. FinCEN relies on the state, territory or tribal characterization of “racino” gaming in determining whether an entity Why is BSA AML Compliance Important? In 1970, Congress passed the Bank Secrecy Act (BSA)—also known as the Anti-Money Laundering (AML) law. Since then, financial institutions like yours have been required to cooperate with government agencies to detect and prevent money laundering. Bank Secrecy Act (BSA) A casino or gambling casino which is a casino for purposes of this chapter solely because its gross annual gaming revenue exceeds $1,000,000 during its current business year, shall not be considered a casino for purposes of this chapter prior to the time in its current business year that its gross annual gaming revenue exceeds $1,000,000. (iii)Any reference in this The definition of a casino as a financial institution includes any branch office. Even though each separate casino license defines a casino as a financial institution for BSA purposes, some casinos may have branch offices to accept payments for debit and credit accounts. Transactions at these branch offices specific to a casino licensee are considered to have occurred by, through or to the At one point, our bank researched the definition of casino to determine if a business is considered a NBFI if they only have video lottery and we found the answer to be No. We are questioning the logic again but cannot find anything concrete to define 'casino' in regards to NBFi status. Can anyone document the true definition of casino in relation to NBFI and advise if a business only has

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