Chapter 8

Title 31 Reporting Requirements

WARNING:  This chapter is far from being the final authority to how your employers expect you to comply with cash transaction reporting requirements. This chapter is written as an attempt to simplify the often confusing subject of 6A reporting as it is required in the State of Nevada and isn’t always applicable in other jurisdictions. You should always check with your supervisors, Title 31 compliance supervisor or accounting department as they have the final say as to how you will meet their requirements. Neither myself, nor this website is responsible for anyone that fails to meet reporting requirements.

Since the late seventies, financial institutions have been required to report cash transactions exceeding $10,000 to the Treasury Department as required by Title 31 of the Bank Secrecy Act using the form that is called a "CTR" which stands for "Currency Transaction Report." The version of this form that is used by casinos is the "CTRC" which stands for "Currency Transaction Report by Casinos" or form FinCEN Form 103.

In 1985, under an agreement with the treasury department, the State of Nevada created the Nevada Gaming Commission Regulation 6A, which became the means for reporting cash transactions by casinos with more the $10,000,000 GAGR (gross annual gaming revenue). The forms used to report transactions are the CTRC-N (Currency Transaction Report by Casinos-Nevada) also known as FinCEN Form 103-N and the Suspicious Activity Report by Casinos (SARC) also known as FinCEN Form 102.

CTR reporting was created to combat money laundering. "Money laundering" is defined by FinCEN as an activity that "involves disguising financial assets so they can be used without detection of the illegal activity that produced them. Through money laundering, the criminal transforms the monetary proceeds derived from criminal activity into funds with an apparently legal source."

The operative word here is "cash." If a transaction doesn’t involve either cash taken from a patron (cash-in) or cash given to a patron (cash-out), then there are no reporting requirements.

Some examples of cash-in transactions are:

Examples of cash-out transactions are:

As a table games floor supervisor, there aren’t any cash-out transactions that you are required to be concerned with. The only cash-in transactions that you are required to report are:

You are not required to combine cash transactions involving departments other than your own.

For the purpose of reporting, your casino is required to combine multiple transactions that occur within the same gaming day. A "gaming day" doesn’t always start at 12:00am and end at 12:00am. The treasury department understands that in the casino business, midnight is a busy time of day and allows casinos to designate their own hours, for the purposes of establishing a gaming day. For example, in the casino I work at, the gaming day starts at 10:00pm and ends at 9:59pm. Obviously, once a casino establishes the hours it will consider a gaming day, it isn’t allowed to change it.

This is called "dissimilar transactions" and can only occur in an "uninterrupted visit." Even if the patron leaves his wife and his chips at the table, while he goes to the restroom, that isn’t considered an "uninterrupted visit." An uninterrupted visit is one where the patron maintains a physical presence at that gaming table.

If a transaction is included in a CTRC-N filed for dissimilar transactions, it can’t be included in another CTRC-N as a transaction can only be reported once.

Once the need to complete a CTRC-N has been established, you will need to get identification from the patron. The transaction cannot be completed until the patron provides identification! Identification is usually a driver’s license but can also be any government issued photo identification or passport. Identification is defined by the Treasury Department as any credential that would normally be considered sufficient for the purposes of cashing a check. An ID with an expired expiration date is acceptable.

Upon obtaining the ID from the patron, you will need to ask him if it has his current address. If he says it does not or if the ID shows a post office box, you will need to ask him for his address and write it down. If a post office box is shown and/or the patron refuses to give you his address, you can still complete the transaction.

You are required to ask the patron for his social security number. You don’t require any proof of it and can write down whatever he tells you it is. If the patron refuses to give you his social security number, you can still complete the transaction. In fact, a Treasury Department agent once told me that they love it when a patron refuses to provide their social security number or gives a false one.

You now have everything you need in order to allow the transaction to continue but you need to take the ID to the podium so you can write down some information. You need to record the type of ID, the issuing agency (usually the state the drivers license came from), the license number, the patron’s address, full name and date of birth. As a physical description will be needed to complete the MTL, you can copy it from the license and then confirm it. Often the pit or shift boss will take the ID to the cage so they can make a copy of it, so it can be kept on file.

Known patron.

If you or your supervisors know this patron, you can complete the transaction without the need for ID, if the following conditions are met:

If the ID used to obtain the information on file has expired, then ID must be obtained for every transaction that requires completing a CTRC-N.

When a known player that is likely to require you to complete a CTRC-N, arrives in your section, you should call your supervisor or the cage to confirm the information on file is up to date.

When you ask a patron to provide you with ID he might ask why you need it. You should tell him something like; "I am required by federal law to see identification in order to complete transactions over ten thousand dollars." You might offer him one of the cards most casinos keep that inform patrons about reporting requirements. You should keep some on you at all times, just for situations like this. You should also read it, as it is a good indicator to how much information you are allowed to give your customers.

Never give the patron any information that could be construed as helping the player evade reporting, such as the time the new gaming day starts!

If the player refuses to complete the transaction or takes back sufficient cash to avoid reporting, you need to notify your supervisor. You will need to give him the game number where the incident took place, the time it happened, the amount of money involved, a description of the patron and whatever information you already have on the patron, possibly from player’s club files. Your supervisor will then make a decision as to whether or not to complete a "SARC" on that player. I would also call surveillance and instruct them to get a picture of the patron.

If the player "pulls back" enough money to avoid reporting, you can still proceed with the transaction, even though you will report the incident. Never inform a patron about the existence of a SARC or that his actions might cause him to have one filed on him.

If it is discovered that identification requirements were not met but the transaction was completed, the customer will be asked to provide identification. If he refuses, he will be barred from any further play and a CTRC-N will be completed with the available information. If the patron later provides ID, he will be unbarred and an "amended" CTRC-N will be completed and filed with the original CTRC-N.

An "agent" is a person that conducts transactions on behalf of a patron. If a patron uses an agent to complete a transaction for him, it will be considered as though the patron completed it himself. The most common occurrence of this is when a patron sends their spouse or friend to the cage to cash-out for them.

A CTRC-N will be completed immediately following the visit in which the transaction occurred that caused it to be required. It will be completed using the amount that is over $10,000 even if the patron is still playing. For example: a player has a total of $9,000 in buy-ins, then buys-in for $2,000 and then buys-in for $3,000. At the end of that visit, a CTRC-N will be completed for a total of $11,000. At the end of the gaming day, a "Supplemental Report" will be completed for the $3,000 and any additional amounts that patron bought in for.

1.) Most of the time you won’t check any of the boxes. You will check (a) Amends prior report, if this is a case of a patron providing ID after a transaction was completed. You will check (b) Supplemental report, if this is a CTRC-N that is being used to add transaction amounts that occurred after the initial CTRC-N was completed.

2.) "Multiple persons" will be checked in the case of two or more patrons were playing from the same bankroll. If this box is checked you will need to use section A of page 2 to record additional persons.

3.) Items 3, 4 and 5 are for the patron’s name.

4.) The patrons physical address, when available.

5.) The patrons social security number or EIN (employer identification number). For non-US citizens, write "None." If the player refused to give his number, write, "Refused."

6.) Write the date of birth using two-digit numbers for the month and day and using a four-digit number, for the year.

7.) This is to record whether identification was established by examining credential or if it was a known patron.

8.) Item 13 is for recording the State and number of the driver’s license used for ID. "d other" is most commonly used in the case the of a military ID, in which case "e" will be "DOD" and "f" will be the patron’s SSN.

9.) You would complete this section if there was an agent involved in the transaction. You include all the information, just as it is required for the patron in Part A. In the case of multiple agents being involved, you would check item 16 and complete Section B of page 2.

10.) No items will be checked if this CTRC-N is for a single transaction. If it is for multiple transactions, item 29 will be checked. Item 30 will be checked in the case of dissimilar transactions exceeding $10,000 in a single uninterrupted visit.

11.) Item 31 is where you write the amounts of cash-in type transactions. The only time you would enter amounts in more than one cash-in type is when you are filing a dissimilar transactions CTRC-N.

12.) The date the transaction occurred.

13.) The time the transaction occurred.

14.) The most common time you will use Item 36 is to indicate which CTRC-N this supplemental report is for. Example: "Supplemental to prior CTRC-N @ 10:15; cumulative $14,000."

15.) Items 37-45 identifies the casino you work at and are usually preprinted for you. If not, you can copy the information from a previously completed CTRC-N.

16.) Print your name and title in Item 46. Sign your name in Item 47. Your ID number may also be required.

17.) The date you signed the form.

18.) Don’t ever write in here. This is for the accounting department that reviews the form for accuracy and completeness.

If you make a mistake, don’t even think about using "white out." You can draw a single line through the mistake, initial it and re-enter the information. However, you will probably prefer to start over with a new form.

The "MTL" or "Multiple Transaction Log" is the form that you will be required to complete far more often than the CTRC-N. A MTL is a form that is used as a tool to enable table games supervisors to track players that could potentially require the completion of a CTRC-N. An entry will be made in the MTL when:

The first entry for a patron will be made when the total of one of these three types of transactions reaches a total of $3001 or more. You need not ask the patron for ID or inform him in any way that you are recording his transactions. When preparing to make an entry in a MTL or notifying your supervisor, so he can do it, you will need the following information:

Besides the player’s name, you will need to know these seven things, in order to complete the player’s physical description:

If I even suspect a player will reach the $3001 threshold, I will write down this information on a scratchpad, so I will have it in case an MTL needs to be completed. As for "attire" they are only looking for the color of the patron’s shirt or jacket and the color of his pants. Example: "Tan shirt/black pants." I will usually compute age by going to the patron’s player account and retrieving his DOB.

If the player is an "un-carded" or R/N, you will write "Refused" in the name section. I won’t write this immediately though, because sometimes you might later learn the patron’s name.

You will write "M" or "F" in the space for sex. You will then use the codes on the left; to determine which letter or number you will write in the spaces.

There will never be an entry made for more than one transaction type per line. You will make the entry for the transaction (or total of transactions) in the space below the transaction type. Under "Cumulative Amounts" you will write the running total for all transactions involving that particular type of transaction, except when it the first entry for that type of transaction. The first time you make an entry for certain transaction type, the cumulative amounts box will be left blank.

You won’t be making an entry every time a patron buys-in. You will make the initial entry when a transaction type exceeds $3,000 and update it when the "visit" at that table ends or when a CTRC-N is required

"White out" will never be used to correct mistakes! Just like the CTRC-N you will draw a single line through the mistake and initial it. If this is the first entry on the MTL, you may wish to start another one. Think before you write! Regardless of how you choose to correct a mistake, it is better if you don’t make one in the first place.

A patron buys-in for $4,000 cash on BJ-1 at 9:00am.

He buys in for $1,000 cash on BJ-2 at 9:15am.

He buys-in for $5,000 on BJ-3 at 9:45am.

He buys-in for $1,000 cash on BJ-4 at 10:30am.

He buys-in for $2,000 cash on BJ-5 at 12:00pm.

During this player’s last visit of the gaming day, at 6:00pm, he buys-in for $20,000 on BJ-6.

The first entry was made at 9:00am when the first qualifying transaction was completed. Notice that the "Cumulative Amount" section is left blank.

At the end of visit 2 an entry was made.

At the end of visit 3 an entry was made. Notice that since the cumulative total is not greater than $10,000, ID was not required and a CTRC-N was not filed.

The $1,000 buy-in on BJ-5 will not be completed unless ID is provided! Although the CTRC-N will be completed at the end of visit 4, it will be completed using the amount of $11,000, even if this patron buys-in with more cash during that visit.

The $2,000 buy-in on BJ-5 brings the patron’s cumulative total to $13,000. However, a supplemental won’t be filed until the end of the gaming day.

ID won’t have to be provided as this is $20,000 buy-in is merely an extension of transaction that occurred on visit 4. A supplemental will be filed for $22,000.

A patron loses a $1,000 money plays wager on BJ-1 at 9:00am.

He then loses a $2,500 money plays wager on BJ-2 at 9:15am.

He then buys-in for $3,100 with cash during the same continuous visit on BJ-2 at 9:30am.

The patron then pays off a $4,000 marker with cash during the same continuous visit on BJ-2 at 9:45am.

The $1,000 losing money plays bet on BJ-1 won’t be logged.

The $2,500 losing money plays bet on BJ-2 will be logged and is to include all previous un-logged losing money plays bets. Some people would merely enter this as "Visit 1." However, there needs to be some way for anyone reading this MTL to be able to ascertain that a there was a reason a dissimilar CTRC-N was not filed, since it would seem that this patron had a total of $10,600 worth of transactions in this visit. Notice in the remarks section "Includes 1,000 on BJ 1" was written to indicate the reason. If visit 2 ended without transactions that exceed $10,000, then the remark wouldn’t be necessary.

The $3,100 cash buy-in exceeds $3,000, so it will be logged.

The $4,000 marker payment with cash exceeds $3,000, so it will be logged.

At the end of the gaming day, "End of day" will be written as shown in every used section of the MTL.

"No Action" will be written in every unused section of the MTL, at the end of the gaming day.

A patron buys-in for $3,500 with cash on BJ-1 at 9:00am.

He then buys-in for $5,000 with cash on BJ-2 at 9:15am.

At 9:30am, in the same single visit at BJ-2, he pays of a $6,000 marker with cash.

At 9:45am, in the same single visit at BJ-2, he loses a $2,000 money plays wager.

At 3:00pm, the patron loses a $2,000 money plays wager on BJ-3.

At 6:00pm, during the patron’s final visit of the gaming day, he buys-in for $1,000 on BJ-4.

The $3,500 buy-in will be logged.

The $5,000 buy-in will be logged.

ID will be required before the $6,000 marker payment with cash is completed because dissimilar transactions during this visit will total $11,000 at this point.

The $2,000 losing money plays wager will be logged at the conclusion of the visit because it will be added to the dissimilar transactions for this visit. At the conclusion of visit 2, a dissimilar CTRC-N will be filed for a total of $13,000.

The $2,000 losing money plays wager on BJ-3 won’t be logged because it isn’t over $3,000 and can’t be added to the $2,000 losing money plays wager on BJ-2, because that transaction was included in the dissimilar CTRC-N.

The $1,000 buy-in on BJ-4 will be logged because it can be added to the $3,500 buy-in on BJ-1, that wasn’t included in the dissimilar CTRC-N. Again, some people might refer to this as "visit 3" but the $2,000 losing money plays wager on BJ-3 could become part of a logged transaction.

Remember, no transactions occurring after visit 2 will be added to the dissimilar CTRC-N because there is never a supplemental completed for a dissimilar CTRC-N.

A patron buys-in for $3,500 on BJ-1 at 9:00am.

He then buys-in for $8,000 on BJ-2 at 9:15am.

During his single visit at BJ-2, he loses an $8,000 money plays bet at 9:30am.

During his single visit at BJ-2, he loses a total of $3,000 in money plays between 9:31am and 10:00am.

He buys-in for $1,500 at CR-3 at 6:00pm.

The $3,500 buy-in will be logged.

ID will be required before the $8,000 buy-in can be completed. A CRTC-N won’t be filed until the end of the visit.

The $8,000 losing money plays bet will be logged immediately, since it is the first of that transaction type that is greater than $3,000. At this point you know that a CTRC-N won’t be filed for the $11,500 buy-in, since now there will be a dissimilar CTRC-N that will take precedence.

The total of all of the patron’s losing bets, the last one being made at 10:00am, is $3,000. A dissimilar CTRC-N will be filed for $19,000.

The $1,500 buy-in will be logged. Notice that the cumulative total is now $5,000, since the $8,000 buy-in was included in the dissimilar CTRC-N.

A similar CTRC-N will be filed using the total that first caused the patron to exceed $10,000, even if that patron completes transactions of that same type, in the same visit. A supplemental will be filed to include all similar transactions that occurred after the CTRC-N was filed, whether they happened later in that single visit or later in the gaming day. However, a dissimilar CTRC-N will be completed for the total of all transaction types that occurred in that single visit.

Once a transaction has been reported in a dissimilar CTRC-N, it is though it never happened.

An expired ID is just as valid as an un-expired one, except in the case of information on file for a known player.

Once the need for identification has been established, a transaction will not be completed unless the patron "pulls back" sufficient cash to avoid reporting. If the patron pulls back, a SARC will be filed. However it is illegal to inform a patron that there is such a thing as a SARC or that his actions will cause him to have one filed.

You don’t require proof of a patron’s social security number, you are only required to make an attempt to obtain the number itself, from the patron.

A "visit", "single visit" and "uninterrupted visit" all mean the same thing. If a patron so much as steps away from a game to talk on his cell phone, the visit ends and the safest thing to do is start recording all transactions as a new visit. This will prevent the need for an unnecessary dissimilar CTRC-N to be filed.

If more spaces are needed to complete transactions for a patron on the MTL: the next available section will be utilized. The name and description are re-entered in the new section; the only difference is that "(Continued)" will be written after the patron’s name.

Some casinos have made an agreement with the Nevada Gaming Commission to report all losing money play wagers and buy-ins as "chip purchases" on craps tables. My sources tell me this was done because some supervisors decided to call certain last second transactions as either money plays or buy-in, depending on which would benefit the patron. Be sure to check with your supervisors to learn the policy for your casino.

Although a $1,000 buy-in is not a reportable transaction, you should notify your supervisor when it occurs. You never know if this player has played in other sections or on other shifts.

It is more important to track transactions on a scratchpad, than even on the drop section of your sweat sheet or the player’s rating slip. You can always update your sweat sheet and rating card at the end of the visit. Make a separate entry for each transaction, including the time it occurred. Draw a line across the pad when a visit ends. Write, "logged" to indicate that the transactions that occurred during that visit were logged on the MTL. Pass this information on to your relief, unless the gaming day has ended.

A "SARC" or "Suspicious Activity Report by Casinos" is a form that is intended to accomplish exactly what it name suggests; report suspicious activity to the Treasury Department. Although you are required to know about it, as floor supervisor you will never be required to complete one. You will merely gather what information is available to you and report the incident or incidents, to your supervisor. If your supervisor decides that the activity was indeed suspicious, he will report to your company’s Reg 6A supervisor, who will make the final decision as to the filing of a SARC.

A customer "pulls back" enough cash to avoid reporting, after being asked for ID.

A patron is observed to intentionally time buy-ins to occur before or after the gaming day, so that each transaction is below $10,000 (structuring transactions).

A patron is observed to conduct a number of currency transactions that are equal to or just below $10,000 (structuring transactions).

A customer may pressure or attempt to induce employees not to file required forms or to record transactions falsely.

A patron may engage in patterns of minimal gaming activity after having performed a casino financial transaction of more than $5,000.

A patron may provide false identification or information, or give conflicting identification information on different days, or refuse to provide his social security number when asked.

Casino employees may learn that patron’s funds are proceeds of illegal activity. Certain unusual activity may also warrant further review, such as a team of bettors observed making large offsetting bets or if a single player is observed making large offsetting bets.

Q: Player A buys-in for $3,000 on BJ-1, pays back a $3,000 marker with cash on BJ-2 and loses $3,000 in money plays bets on BJ-3. Player B buys in for $3,000, pays back a $3,000 marker with cash and loses $3,000 in money plays bets, all in one uninterrupted visit on BJ-1. What reporting actions will you take for each player?

A: None. Neither player exceeded $3,000 in any of the transaction types and Player B did not exceed $10,000 in his uninterrupted visit.

Q: A player buys-in for $6,000 cash, pays back a $2,000 marker with cash and loses a $3,000 money plays bet all in one uninterrupted visit. A dissimilar CTRC-N is completed. The player later, in the same gaming day, buys-in for $5,000. What are the reporting requirements, if any, for the $5,000 buy-in?

A: Even though the player’s total buy-ins for the day is $11,000, the first $6,000 was included in the dissimilar CTRC-N and can’t be reported twice. The only action would be to log the $5,000 on the MTL, since it is over $3,000. A supplemental is never filed for a dissimilar CTRC-N.

Q: In one uninterrupted visit, a player buys-in for $6,000, then buys-in for $5,000 and then pays back a $2,000 maker with cash. What are the reporting requirements?

A: The $6000 will be logged on the MTL. ID will be acquired from the patron before the $5,000 buy-in is completed. The $5,000 will be logged on the MTL. At the end of the visit, the $2,000 marker payment will be logged and a dissimilar CTRC-N will be completed for $13,000. Dissimilar CTRC-N’s always take precedence over a similar CTRC-N.

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