Financial Crimes Enforcement Network Advisory: Structuring by Casino Patrons and Personnel, July 1, 2009 [open pdf - 75KB]
"The Financial Crimes Enforcement Network ('FinCEN') recently received information from law enforcement and regulatory authorities that certain casino personnel may have complied with requests from patrons to evade, or provided instructions to patrons on how to evade, reporting and recordkeeping requirements under the Bank Secrecy Act ('BSA'). It appears that casino patrons and personnel may have engaged in 'structuring' certain transactions to evade such requirements. The BSA prohibits any person, for the purpose of evading the requirement to report currency transactions or evading recordkeeping requirements under the BSA, from causing or attempting to cause a casino not to file a currency transaction report, to file a currency transaction report with material misstatements or omissions, not to maintain records required under the BSA, or to maintain these records in a form that is incomplete or inaccurate. FinCEN is issuing this advisory to remind casinos and card clubs that structuring is unlawful, and that such activity can give rise to significant civil and criminal penalties under the BSA. FinCEN is authorized to impose civil money penalties against casinos violating the BSA, and the U.S. Department of Justice prosecutes criminal violations of the BSA and related money-laundering statutes."
FinCEN Advisory FIN-2009-A003
Financial Crimes Enforcement Network: http://www.fincen.gov