Casino Player Card Fraud
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Online casinos along with the other service providers involved offer certain facilities to the players. If the players use these facilities in the true spirit then the entire system runs like a well-oiled machine and everyone benefits. However if the players abuse the facilities given then everyone suffers.
*Casino Player Club Card Scams
*Casino Player Card Fraud Against
*Casino Player Card Fraud Statute Of Limitations
Cheating in casinos refers to actions by the player or the house which are prohibited by regional gambling control authorities. This may involve using suspect apparatus, interfering with apparatus, chip fraud or misrepresenting games. Hi all, If you use your friends players card and you win over $1200, who is credited with the win, you or the friend? What happens if it’s over $100,000 or more? I was just wondering because every once in a while, I’ll use my friends card to help him boost his RC. Then I got to thinking what would happen if I actually hit it big while using his. The document went on to allege that Postle also likely committed wire fraud if it is his cell phone that allowed him access to the hole cards of the other players. Player results and casino.
One common abuse that is most reported by online casinos is players informing credit card companies that they did not make the transactions depositing funds in online casinos and therefore their account should be credited or ’charged back’. Credit cards offer credit to their users. The users can pay online or offline using the credit cards without any money being paid. The credit card company then pays the vendor and charges the credit card user in a consolidated monthly statement. Players use their credit cards to fund online casino accounts. The credit card company clears the funds to the online casino and the player starts wagering. When the player receives the statement from the credit card company he denies having sanctioned the payment and demands a charge back.
This forces the credit card company and the online casino to carry out an investigation. Such investigations are an unnecessary cost to these organizations and hence are not appreciated. Pending investigation the credit card company may hold the actual transfer of funds to the online casino. The online casino will definitely prevent the customer from using its services. And the player cannot hope to get away with this. The transactions are made through secure channels that prevent abuse. Also the details of the transaction are recorded and archived and hence can be retrieved for investigation. The security processes in place are so strong that not only the exact date and time of the transaction is known but also the IP address of the computer from which the transaction was carried out. Hence due investigation will prove that the player made the transaction. Only a lot of people would have spent time and effort and unnecessary cost would have been incurred.
Both the online casinos and credit card companies consider illegitimate charging back as fraud and the consequences for the player are disastrous. The credit card company will cancel the card and therefore the player will not be able to use it for other purposes as well. In addition the credit card company will pursue all means at its disposal to recover the dues. The online casino will eject the player and block him from participating again. And if the player is under the impression that there are other credit card providers and other online casinos then he is mistaken. Both online casinos and credit card providers share information about fraudulent clients so the player may find his other memberships being blocked as well and his applications elsewhere will be turned down.
Hence gamble responsibly and do not try to recoup losses using fraudulent means because you will be caught and be worse off than before.Comments Add CommentComment by: affiliateman On: September 11, 2010
I myself am an affiliate in the gaming industry online. I make my money promoting various online casinos, sportsbooks, bingo and poker rooms. I have to agree with phizzle here. Especially on the ethics part. I for one am someone who makes their living off of this industry and every time there is a charge back that’s issued with one of the players that I’ve brought into a casino I get screwed. I get screwed in that any monies that they’ve played though will eventually be withdrawn from my account balance thus making it far more volatile to be in this industry. It was much better when NETeller and Paypal were still viable options and pushed more heavily by online casinos in the US as charge backs were far more difficult with these banking options. Unfortunately you can charge back like Arnold does say but lots of people do get screwed as a result. I agree to in that it’s no different then purchasing some kind of good and calling the credit card company telling them that you didn’t in fact make the transaction when you did. In both cases you’re lying to the credit card company and that in itself is unethical. Comment by: Arnold On: September 10, 2010
Come on, no one has been burnt by charging back. There is no harm in trying. The worst case scenario is that your credit card company refuses the chargeback, which is actually quite unlikely. Remember, when you use a credit card, it is not the customer who is making the transaction, it is the credit card company. So if the credit card company rules in your favor, then the vendor CANNOT go after you directly. The credit card company has already determined it is fraud, and the only way a vendor can collect is to go after the credit card company directly. There is ABSOLUTELY no legal standing to go after the customer directly. This is why people use credit cards. Now, let me see a online casino or third party vendor sue VISA or AMEX for not processing their funds. Yeh, good luck. Once again, the consequences of chargebacks are not that the vendor can come after you. They simply cannot. It is that your own credit card company may brand you ’high risk’ if you do a lot of chargebacks, but that is only if you do a lot. And you get kicked off your site and get on some kind of blacklist. But once again, there are hundreds/thousands of sites that all want your business, so this is not a big deal. Fraudsters who charge back routinely playing the big back -- cash in / lose -- chargeback may have some trouble doing this continuously with their own credit card company as they may start to wonder what the hell you are doing. But each individual charge can be charged back. Eventually though, the credit card company may reduce your credit limit, increase your rates, or cancel you, but they will always process your chargebacks, as in reality, the chargebacks are legitimate as you did not receive random internet purchases as it states you did. And don’t play the ethics game. It is not ethical to accept US players in the first place. Comment by: Arnold On: September 09, 2010
Um, Andrew is 100% correct. Chargebacks can be done routinely. Almost always, it falls in favor of the customer. This is primarily because the vendor does not want to expose themselves once a chargeback inquiry takes place, and doesn’t have much to stand on anyway. They just write it off and move on. However, there are consequences of chargebacks for the customer -- they can get kicked off site (who cares, there are hundreds of others), they can get blacklisted (once again, there are hundreds so you can always find one that will accept your business), or their credit card company can start getting suspicious and cancel you if you have too many chargebacks (it takes effort for them to investigate each one, and they wont appreciate lots of them). However, if you lost a lot of money and don’t play online regularly, then it probably is in your best interest to chargeback if you lost. Or you can bet big and see if you win and otherwise charge back, but once again this can’t be done continuously. But it is all factored in. The online casinos aren’t really ’losing’ anything if you charge back, just a few minutes on their software. So they will happily take credit cards all day from US players knowing that chargebacks will occur periodically, since by not taking US credit cards they will lose out. They try (on this site) to scare you from charging back, but if you are on this site and are thinking about it, then go for it. I have charged back $5000 from various cards and have won every time. I still can get on plenty of sites so I am not sure what this mythical blacklist is anyway. Go for it.. Comment by: Kinton Karling On: August 11, 2010
To be honest ’Andrew’ who commented below is _NOT_ correct and you should not take his advice. He’s obviously never charged back and gotten into problems for doing so. Whenever you sign something that indicates a commitment you’re obligated to that commitment. If you do want to get away with chargebacks just make sure you never sign any documents required by the casino and their fax-back due diligence progress. Furthermore it’s just not ethical even in the event that you could get away with it. Consider the fact that you purchase any good and just because you feel like it you decide to screw over the merchant if every one was to do this for all other industries gambling included it would create havoc. Comment by: Andrew On: August 09, 2010
You are wrong with most of this. Chargebacks are usually in the favor of the customer, especially since online casinos are illegal in the US and have to use third parties to bill. Most of the time, you will have your money refunded. The credit card WILL NOT be cancelled. You may be blacklisted, however, from that and other online sites. This is a big problem in the industry -- folks who sign up, bet big, collect their winnings if they win and chargeback their deposit if they lose. But there isn’t much the casino can do about it, it is just factored in to their overall budget. Chargebacks are perfectly legal and acceptable to players since the casino is illegally funneling money through third party vendors, which is deceiptful in their own right. The only way to stop this is for sites to not accept credit cards, but they don’t want to do that since that would hurt business. So now that we found the secret, chargeback as much as you can until you get blacklisted or win! Comment by: Melissa J. On: December 27, 2009
I’ve done it in the past but only when I didn’t realize that the charges were legitimate. When I tried playing at the casino that I normally play at they locked my account because of the charge back which was obviously within their right to do 100% but the fact is that it caused a lot of problems for me by charging back. If you’re going to do it be absolutely certain that you’re not in the wrong about it. Comment by: Channy On: December 18, 2009
It’s dishonest to charge back transactions if in fact you’re the one that made them. I don’t think it’s right when people do this. I know that I for one would only charge back something if in fact I didn’t make such charges that appeared on my credit card statement. Comment by: Juda On: September 25, 2009
I’m with you all it’s a big mistake to charge back legitimate transactions on your credit card. Also something to keep in mind is that it will and does affect your credit rating so it’s really not worth it! Comment by: Laney B. On: September 13, 2009
I’m in agreement with everyone on this subject as well. I beleive that charging back is only worth it if in fact you didn’t make the charge that you’re seeing come though on your credit card. It’s always wise to inspect the charge before contacting your bank and requesting that they issue the charge back. Comment by: Karl Benton On: August 31, 2009
If you charge back you will be blacklisted by online casinos. Also if the payment processing companies that online casino providers are the same as some of those that process transactions for online bingo companies, poker rooms and other forms of online gambling you may find that you won’t be able to play any of those either. So just be aware that there are repercussions with charging back. Comment by: Rubin On: August 27, 2009
I too don’t think that charging back is a good idea if the transactions that are showing up on your monthly statement are in fact legitimate transactions. It doesn’t to anyone any good. You might thing you’re doing yourself a favor by getting some money back this way but in the end it’s more damaging to charge back transactions then it’s worth. Comment by: Danny Spicer On: August 14, 2009
From what I understand individual casinos along with software providers and also many of the payments companies that online casinos work with hold blacklists of players that have charged back. Unless you legitimately didn’t make transactions that you’re seeing on your credit card bill should you charge back otherwise I just don’t think it’s worth the implications that follow. Comment by: Laney B. On: August 10, 2009
Yeah agreed issuing charge backs is not something you really want to do and something that you want to avoid as much as possible if you can. I think that if you do decide to charge back transactions you know you’ve made at an online casino you should be prepared to encounter issues if you play again in the future especially if you’re name is logged on the software provider level. Comment by: Angie Kent On: July 28, 2009
I fully agree with this tip charging back is not worth it. Not only does it make you look bad to the credit card companies but it’s also a problems that you’ll encounter after doing this and your ability to continue playing. These negative database that online casinos store that contain information about all those who’ve charged back are being used more and more from what I understand so avoid doing it all together unless you never want to play at an online casino, poker room, sportsbook or bingo room again. Add Comment You must be signed-in to add a comment: - Sign-in- Register
FIN-2012-G004 Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
This document provides guidance interpreting the requirements of the Bank Secrecy Act (’BSA’) regulations1 as they apply to the casino and card club industries in the United States. FinCEN additionally published frequently asked questions for casinos and card clubs as FIN-2007-G005 on November 14, 2007 and FIN-2009-G004 on September 30, 2009. Casinos and card clubs may continue to rely on the guidance contained in FIN-2007-G005 and FIN-2009-G004, which have not been incorporated into this publication. Section A: 31 C.F.R. § 1010.100 Casino and Card Club DefinitionsQuestion 1: Are two separately licensed, but jointly-owned tribal gaming operations, one of which is a bingo hall and the other offering casino games, both treated as casinos under the BSA regulations?
Answer 1: If a tribal government issues two separate licenses, one for a tribal gaming operation that only offers traditional bingo, and one for a tribal gaming operation that offers casino games, the former is not treated as a casino under BSA regulations, while the latter is treated as a casino under BSA regulations.2 Joint ownership is not relevant to the determination. See FIN-2007-G005 (Nov. 14, 2007), Question and Answer 2, concerning the treatment of bingo. Question 2: Is a casino or a card club that cashes checks considered a money services business (’MSB’)?
Answer 2: No. A casino or a card club that is duly licensed or authorized to do business as such, and has gross annual gaming revenue in excess of $1 million, is subject to the requirements applicable to casinos or card clubs, even if a casino or card club does its own check cashing. A casino or a card club is not required to comply with rules specific to MSBs.3 Section B: 31 C.F.R. §§ 1021.311(a) - (c) and 1021.313 Currency Transaction Reporting RequirementsQuestion 3: Can a casino comply with currency transaction reporting requirements by using a ’two-strike’ system to obtain identifying information for customers purchasing chips in multiple transactions?
Answer 3: FinCEN is aware that some casinos use a so-called ’two-strike’ system (or possibly a similarly designed system) to obtain customer identifying information related to reportable currency transactions involving multiple chip purchases during a gaming day. Rather than obtaining information directly from a customer during a transaction, the casino relies upon computer or other pre-existing internal records to identify transactions and obtain the identifying information (e.g., Social Security Number, an address) needed to complete a currency transaction report. If the necessary identifying information is absent or incomplete, the casino will file an incomplete report and enter the name of the customer into a computerized database.
When the same customer returns to the casino on another gaming day and purchases $5,000 or more in chips with currency, the casino will check a computerized database to determine if an incomplete report had previously been filed. The casino will ask the customer for any omitted identifying information. If the customer refuses to provide the information and the customer purchases chips for less than $10,000, the casino will wait until the customer’s currency activity exceeds $10,000, at which point it will again request identifying information. If the customer refuses to provide the information, then the customer is banned from further cash buy-ins until the information is produced or until the expiration of six months.
A ’two-strike’ system could result in the filing of two incomplete currency transaction reports. The casino has knowledge that the same customer has conducted transactions in amounts aggregating to more than $10,000 during a single gaming day. A casino has 15 gaming days to file a complete report. If a casino has a reasonable opportunity to obtain identifying information from a customer, but instead relies on inaccurate or incomplete information in pre-existing internal records, the casino has not complied with the regulations.Question 4: Is a card club required to create and retain records of all currency transactions related to Kum Kum betting?
Answer 4: The regulations implementing the BSA require card clubs to create and to retain records of all currency transactions by customers, including records in the form of currency transaction logs and multiple currency transaction logs.4 This requirement applies to card clubs that offer the practice of Kum Kum betting and banking.5 In Kum Kum betting, bets are broken into a ratio or evenly split among individuals in a partnership, and wins or losses are divided among the individuals. An individual placing a Kum Kum bet must exchange currency for chips with a card club dealer or chip runner before a Kum Kum bet is accepted.
The regulations require a card club to file a currency transaction report for each transact
https://diarynote-jp.indered.space
Online casinos along with the other service providers involved offer certain facilities to the players. If the players use these facilities in the true spirit then the entire system runs like a well-oiled machine and everyone benefits. However if the players abuse the facilities given then everyone suffers.
*Casino Player Club Card Scams
*Casino Player Card Fraud Against
*Casino Player Card Fraud Statute Of Limitations
Cheating in casinos refers to actions by the player or the house which are prohibited by regional gambling control authorities. This may involve using suspect apparatus, interfering with apparatus, chip fraud or misrepresenting games. Hi all, If you use your friends players card and you win over $1200, who is credited with the win, you or the friend? What happens if it’s over $100,000 or more? I was just wondering because every once in a while, I’ll use my friends card to help him boost his RC. Then I got to thinking what would happen if I actually hit it big while using his. The document went on to allege that Postle also likely committed wire fraud if it is his cell phone that allowed him access to the hole cards of the other players. Player results and casino.
One common abuse that is most reported by online casinos is players informing credit card companies that they did not make the transactions depositing funds in online casinos and therefore their account should be credited or ’charged back’. Credit cards offer credit to their users. The users can pay online or offline using the credit cards without any money being paid. The credit card company then pays the vendor and charges the credit card user in a consolidated monthly statement. Players use their credit cards to fund online casino accounts. The credit card company clears the funds to the online casino and the player starts wagering. When the player receives the statement from the credit card company he denies having sanctioned the payment and demands a charge back.
This forces the credit card company and the online casino to carry out an investigation. Such investigations are an unnecessary cost to these organizations and hence are not appreciated. Pending investigation the credit card company may hold the actual transfer of funds to the online casino. The online casino will definitely prevent the customer from using its services. And the player cannot hope to get away with this. The transactions are made through secure channels that prevent abuse. Also the details of the transaction are recorded and archived and hence can be retrieved for investigation. The security processes in place are so strong that not only the exact date and time of the transaction is known but also the IP address of the computer from which the transaction was carried out. Hence due investigation will prove that the player made the transaction. Only a lot of people would have spent time and effort and unnecessary cost would have been incurred.
Both the online casinos and credit card companies consider illegitimate charging back as fraud and the consequences for the player are disastrous. The credit card company will cancel the card and therefore the player will not be able to use it for other purposes as well. In addition the credit card company will pursue all means at its disposal to recover the dues. The online casino will eject the player and block him from participating again. And if the player is under the impression that there are other credit card providers and other online casinos then he is mistaken. Both online casinos and credit card providers share information about fraudulent clients so the player may find his other memberships being blocked as well and his applications elsewhere will be turned down.
Hence gamble responsibly and do not try to recoup losses using fraudulent means because you will be caught and be worse off than before.Comments Add CommentComment by: affiliateman On: September 11, 2010
I myself am an affiliate in the gaming industry online. I make my money promoting various online casinos, sportsbooks, bingo and poker rooms. I have to agree with phizzle here. Especially on the ethics part. I for one am someone who makes their living off of this industry and every time there is a charge back that’s issued with one of the players that I’ve brought into a casino I get screwed. I get screwed in that any monies that they’ve played though will eventually be withdrawn from my account balance thus making it far more volatile to be in this industry. It was much better when NETeller and Paypal were still viable options and pushed more heavily by online casinos in the US as charge backs were far more difficult with these banking options. Unfortunately you can charge back like Arnold does say but lots of people do get screwed as a result. I agree to in that it’s no different then purchasing some kind of good and calling the credit card company telling them that you didn’t in fact make the transaction when you did. In both cases you’re lying to the credit card company and that in itself is unethical. Comment by: Arnold On: September 10, 2010
Come on, no one has been burnt by charging back. There is no harm in trying. The worst case scenario is that your credit card company refuses the chargeback, which is actually quite unlikely. Remember, when you use a credit card, it is not the customer who is making the transaction, it is the credit card company. So if the credit card company rules in your favor, then the vendor CANNOT go after you directly. The credit card company has already determined it is fraud, and the only way a vendor can collect is to go after the credit card company directly. There is ABSOLUTELY no legal standing to go after the customer directly. This is why people use credit cards. Now, let me see a online casino or third party vendor sue VISA or AMEX for not processing their funds. Yeh, good luck. Once again, the consequences of chargebacks are not that the vendor can come after you. They simply cannot. It is that your own credit card company may brand you ’high risk’ if you do a lot of chargebacks, but that is only if you do a lot. And you get kicked off your site and get on some kind of blacklist. But once again, there are hundreds/thousands of sites that all want your business, so this is not a big deal. Fraudsters who charge back routinely playing the big back -- cash in / lose -- chargeback may have some trouble doing this continuously with their own credit card company as they may start to wonder what the hell you are doing. But each individual charge can be charged back. Eventually though, the credit card company may reduce your credit limit, increase your rates, or cancel you, but they will always process your chargebacks, as in reality, the chargebacks are legitimate as you did not receive random internet purchases as it states you did. And don’t play the ethics game. It is not ethical to accept US players in the first place. Comment by: Arnold On: September 09, 2010
Um, Andrew is 100% correct. Chargebacks can be done routinely. Almost always, it falls in favor of the customer. This is primarily because the vendor does not want to expose themselves once a chargeback inquiry takes place, and doesn’t have much to stand on anyway. They just write it off and move on. However, there are consequences of chargebacks for the customer -- they can get kicked off site (who cares, there are hundreds of others), they can get blacklisted (once again, there are hundreds so you can always find one that will accept your business), or their credit card company can start getting suspicious and cancel you if you have too many chargebacks (it takes effort for them to investigate each one, and they wont appreciate lots of them). However, if you lost a lot of money and don’t play online regularly, then it probably is in your best interest to chargeback if you lost. Or you can bet big and see if you win and otherwise charge back, but once again this can’t be done continuously. But it is all factored in. The online casinos aren’t really ’losing’ anything if you charge back, just a few minutes on their software. So they will happily take credit cards all day from US players knowing that chargebacks will occur periodically, since by not taking US credit cards they will lose out. They try (on this site) to scare you from charging back, but if you are on this site and are thinking about it, then go for it. I have charged back $5000 from various cards and have won every time. I still can get on plenty of sites so I am not sure what this mythical blacklist is anyway. Go for it.. Comment by: Kinton Karling On: August 11, 2010
To be honest ’Andrew’ who commented below is _NOT_ correct and you should not take his advice. He’s obviously never charged back and gotten into problems for doing so. Whenever you sign something that indicates a commitment you’re obligated to that commitment. If you do want to get away with chargebacks just make sure you never sign any documents required by the casino and their fax-back due diligence progress. Furthermore it’s just not ethical even in the event that you could get away with it. Consider the fact that you purchase any good and just because you feel like it you decide to screw over the merchant if every one was to do this for all other industries gambling included it would create havoc. Comment by: Andrew On: August 09, 2010
You are wrong with most of this. Chargebacks are usually in the favor of the customer, especially since online casinos are illegal in the US and have to use third parties to bill. Most of the time, you will have your money refunded. The credit card WILL NOT be cancelled. You may be blacklisted, however, from that and other online sites. This is a big problem in the industry -- folks who sign up, bet big, collect their winnings if they win and chargeback their deposit if they lose. But there isn’t much the casino can do about it, it is just factored in to their overall budget. Chargebacks are perfectly legal and acceptable to players since the casino is illegally funneling money through third party vendors, which is deceiptful in their own right. The only way to stop this is for sites to not accept credit cards, but they don’t want to do that since that would hurt business. So now that we found the secret, chargeback as much as you can until you get blacklisted or win! Comment by: Melissa J. On: December 27, 2009
I’ve done it in the past but only when I didn’t realize that the charges were legitimate. When I tried playing at the casino that I normally play at they locked my account because of the charge back which was obviously within their right to do 100% but the fact is that it caused a lot of problems for me by charging back. If you’re going to do it be absolutely certain that you’re not in the wrong about it. Comment by: Channy On: December 18, 2009
It’s dishonest to charge back transactions if in fact you’re the one that made them. I don’t think it’s right when people do this. I know that I for one would only charge back something if in fact I didn’t make such charges that appeared on my credit card statement. Comment by: Juda On: September 25, 2009
I’m with you all it’s a big mistake to charge back legitimate transactions on your credit card. Also something to keep in mind is that it will and does affect your credit rating so it’s really not worth it! Comment by: Laney B. On: September 13, 2009
I’m in agreement with everyone on this subject as well. I beleive that charging back is only worth it if in fact you didn’t make the charge that you’re seeing come though on your credit card. It’s always wise to inspect the charge before contacting your bank and requesting that they issue the charge back. Comment by: Karl Benton On: August 31, 2009
If you charge back you will be blacklisted by online casinos. Also if the payment processing companies that online casino providers are the same as some of those that process transactions for online bingo companies, poker rooms and other forms of online gambling you may find that you won’t be able to play any of those either. So just be aware that there are repercussions with charging back. Comment by: Rubin On: August 27, 2009
I too don’t think that charging back is a good idea if the transactions that are showing up on your monthly statement are in fact legitimate transactions. It doesn’t to anyone any good. You might thing you’re doing yourself a favor by getting some money back this way but in the end it’s more damaging to charge back transactions then it’s worth. Comment by: Danny Spicer On: August 14, 2009
From what I understand individual casinos along with software providers and also many of the payments companies that online casinos work with hold blacklists of players that have charged back. Unless you legitimately didn’t make transactions that you’re seeing on your credit card bill should you charge back otherwise I just don’t think it’s worth the implications that follow. Comment by: Laney B. On: August 10, 2009
Yeah agreed issuing charge backs is not something you really want to do and something that you want to avoid as much as possible if you can. I think that if you do decide to charge back transactions you know you’ve made at an online casino you should be prepared to encounter issues if you play again in the future especially if you’re name is logged on the software provider level. Comment by: Angie Kent On: July 28, 2009
I fully agree with this tip charging back is not worth it. Not only does it make you look bad to the credit card companies but it’s also a problems that you’ll encounter after doing this and your ability to continue playing. These negative database that online casinos store that contain information about all those who’ve charged back are being used more and more from what I understand so avoid doing it all together unless you never want to play at an online casino, poker room, sportsbook or bingo room again. Add Comment You must be signed-in to add a comment: - Sign-in- Register
FIN-2012-G004 Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
This document provides guidance interpreting the requirements of the Bank Secrecy Act (’BSA’) regulations1 as they apply to the casino and card club industries in the United States. FinCEN additionally published frequently asked questions for casinos and card clubs as FIN-2007-G005 on November 14, 2007 and FIN-2009-G004 on September 30, 2009. Casinos and card clubs may continue to rely on the guidance contained in FIN-2007-G005 and FIN-2009-G004, which have not been incorporated into this publication. Section A: 31 C.F.R. § 1010.100 Casino and Card Club DefinitionsQuestion 1: Are two separately licensed, but jointly-owned tribal gaming operations, one of which is a bingo hall and the other offering casino games, both treated as casinos under the BSA regulations?
Answer 1: If a tribal government issues two separate licenses, one for a tribal gaming operation that only offers traditional bingo, and one for a tribal gaming operation that offers casino games, the former is not treated as a casino under BSA regulations, while the latter is treated as a casino under BSA regulations.2 Joint ownership is not relevant to the determination. See FIN-2007-G005 (Nov. 14, 2007), Question and Answer 2, concerning the treatment of bingo. Question 2: Is a casino or a card club that cashes checks considered a money services business (’MSB’)?
Answer 2: No. A casino or a card club that is duly licensed or authorized to do business as such, and has gross annual gaming revenue in excess of $1 million, is subject to the requirements applicable to casinos or card clubs, even if a casino or card club does its own check cashing. A casino or a card club is not required to comply with rules specific to MSBs.3 Section B: 31 C.F.R. §§ 1021.311(a) - (c) and 1021.313 Currency Transaction Reporting RequirementsQuestion 3: Can a casino comply with currency transaction reporting requirements by using a ’two-strike’ system to obtain identifying information for customers purchasing chips in multiple transactions?
Answer 3: FinCEN is aware that some casinos use a so-called ’two-strike’ system (or possibly a similarly designed system) to obtain customer identifying information related to reportable currency transactions involving multiple chip purchases during a gaming day. Rather than obtaining information directly from a customer during a transaction, the casino relies upon computer or other pre-existing internal records to identify transactions and obtain the identifying information (e.g., Social Security Number, an address) needed to complete a currency transaction report. If the necessary identifying information is absent or incomplete, the casino will file an incomplete report and enter the name of the customer into a computerized database.
When the same customer returns to the casino on another gaming day and purchases $5,000 or more in chips with currency, the casino will check a computerized database to determine if an incomplete report had previously been filed. The casino will ask the customer for any omitted identifying information. If the customer refuses to provide the information and the customer purchases chips for less than $10,000, the casino will wait until the customer’s currency activity exceeds $10,000, at which point it will again request identifying information. If the customer refuses to provide the information, then the customer is banned from further cash buy-ins until the information is produced or until the expiration of six months.
A ’two-strike’ system could result in the filing of two incomplete currency transaction reports. The casino has knowledge that the same customer has conducted transactions in amounts aggregating to more than $10,000 during a single gaming day. A casino has 15 gaming days to file a complete report. If a casino has a reasonable opportunity to obtain identifying information from a customer, but instead relies on inaccurate or incomplete information in pre-existing internal records, the casino has not complied with the regulations.Question 4: Is a card club required to create and retain records of all currency transactions related to Kum Kum betting?
Answer 4: The regulations implementing the BSA require card clubs to create and to retain records of all currency transactions by customers, including records in the form of currency transaction logs and multiple currency transaction logs.4 This requirement applies to card clubs that offer the practice of Kum Kum betting and banking.5 In Kum Kum betting, bets are broken into a ratio or evenly split among individuals in a partnership, and wins or losses are divided among the individuals. An individual placing a Kum Kum bet must exchange currency for chips with a card club dealer or chip runner before a Kum Kum bet is accepted.
The regulations require a card club to file a currency transaction report for each transact
https://diarynote-jp.indered.space
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