Slots Internal Controls
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OPSW 15 controls the speed value, can be set to force speed value to 00 upon purge. This prevents runaways from happening should an address be purged while a train is in motion. Slot Following refers to operation of a stolen locomotive. Internal Control Minimum Procedures (ICMP) secured compartment and there need not be any other secured compartment within the slot machine itself that in which the internal logic is to reside to satisfy this regulation. DEVICE STORAGE, MOVEMENT REPORTING AND DESTRUCTION.
*Slots Internal Controls Software
*Slots Internal Controls
*Slots Internal Controls Jobs
*Slots Internal Controls Switch
*Slots Internal Controls ComponentsIntroduction to West Virginia Slot Machine Casino Gambling in 2020
West Virginia slot machine casino gambling consists of five casinos including one casino resort and four racetracks with slot machines. Many retailers have a few video lottery terminals.
The West Virginia state legislature has two sets of minimum and maximum theoretical payout limits depending upon the location of the gaming machine. Limited return statistics are available annually.
This post continues my weekly State-By-State Slot Machine Casino Gambling Series, an online resource dedicated to guiding slot machine casino gambler to success. Now in its third year, each weekly post reviews slots gambling in a single U.S. state, territory, or federal district.Slots Internal Controls SoftwareKeep Reading … Or Watch Instead!Or … Listen Instead!
Find my podcast wherever you listen to audio!Relevant Legal Statutes on Gambling in West Virginia*
The minimum legal gambling age in West Virginia depends upon the gambling activity:
*Land-Based Casinos: 21
*Poker Rooms: 21
*Bingo: 18
*Lottery: 18
*Pari-Mutuel Wagering: 21
In 1994, West Virginia legalized video lottery terminals at their thoroughbred and greyhound racetracks. In 1999, West Virginia began allowing physical reel slot machines at licensed racetracks.
Machine restrictions at these pari-mutuel wagering facilities include approval by the local county and having only:
*Slots
*Blackjack
*Keno
*Many versions of poker
In 2001, West Virginia passed the Limited Video Lottery Act allowing bars and restaurants to have up to five video lottery terminals (VLTs) and fraternal organizations to have up to ten VLTs. The Act also restricted the state to a total of 9,000 VLTs.
*The purpose of this section is to inform the public of state gambling laws and how the laws might apply to various forms of gaming. It is not legal advice.Slot Machine Private Ownership in West Virginia
It is legal to own a slot machine privately in West Virginia.Gaming Control Board in West Virginia
The West Virginia Lottery Commission controls VLT gaming regulations. This lottery was created in 1984 by amending the Constitution of West Virginia with Article VI, Section 36.
Afterward, West Virginia legalized VLTs with subsequent amendments, acts, rules, and statutes. Each statute is available in the West Virginia Lottery’s Rules and Regulations.Casinos in West Virginia
There are four pari-mutuel racetracks and one casino resort in West Virginia, where their slot machines have 18 different games. In 2019, 1,303 commercial retailers each had between five and ten VLTs, offering eleven games.
The largest casino in West Virginia is Hollywood Casino at Charles Town Races with 2,500 slot machines. Porchville.
The second-largest casino is Mountaineer Casino Racetrack & Resort with 1,525 slot machines.Commercial Casinos in West Virginia
The four pari-mutuel racetracks with slot machines in West Virginia are:
*Hollywood Casino at Charles Town Races in Charles Town, 320 miles northeast of Charleston.
*Mardi Gras Casino & Resort in Cross Lanes, 10 miles northwest of Charleston.
*Mountaineer Casino Racetrack & Resort in New Cumberland, 35 miles north of Wheeling.
*Wheeling Island Hotel Casino Racetrack in Wheeling.
The single casino resort in West Virginia is:
*The Casino Club at The Greenbrier in White Sulphur Springs, 120 miles southeast of CharlestonTribal Casinos in West Virginia
West Virginia has no federally-recognized tribes and, therefore, no tribal casinos.Other Gambling Establishments
As an alternative to enjoying West Virginia slot machine casino gambling, consider exploring casino options in a nearby state. Bordering West Virginia is:
*North: Maryland Slots and Pennsylvania Slots
*East and South: Virginia Slots
*West: Kentucky Slots and Ohio Slots
Each of the links above will take you to my blog for that neighboring U.S. state to West Virginia.Our West Virginia Slots Facebook Group
Are you interested in sharing and learning with other slots enthusiasts in West Virginia? If so, join our West Virginia slots community on Facebook. All you’ll need is a Facebook profile to join this closed Facebook Group freely.
There, you’ll be able to privately share your slots experiences as well as chat with players about slots gambling in West Virginia. Join us!Payout Returns in West Virginia
West Virginia has two sets of theoretical payout limits including:
*Racetracks and casino resort: 80% and 99.9%
*Commercial retailers: 80% and 92% (or 95%, if approved)
Retailers must obtain individual permissions to have a greater than 92% payout. These high payout terminals must obtain Commission approval twice, including:
Written consent prior to manufacturing
Approval before applying for testing
From its 2019 Annual Report, the Commission reported the annual return statistics in West Virginia to be:
*Casino resort: 92.5%
*Racetracks: 89.6%
*Commercial Retailers: 92.1%Summary of West Virginia Slot Machine Casino Gambling in 2020
West Virginia slot machine casino gambling consists of one casino resort, four racetracks, and 1,303 retailers with VLT-style gaming machines. Retailers may have up to five VLTs if a bar or tavern, and up to ten VLTs if a fraternal organization. Up to 18 different games are available on these VLTs, including slot machine game themes.
The minimum theoretical payout is 80% for all VLTs. The maximum theoretical payout is 99.9% for casinos, but 92% for retailers. With permissions, retailers can obtain a 95% maximum theoretical payout for specific VLT machines.Annual Progress in West Virginia Slot Machine Casino Gambling
Over the last year, there has been no change in the West Virginia gaming industry.Other State-By-State Articles from Professor Slots
*Previous: Washington Slot Machine Casino Gambling
*Next: Wisconsin Slot Machine Casino Gambling
Have fun, be safe, and make good choices!
By Jon H. Friedl, Jr. Ph.D., President
Jon Friedl, LLCFIN-2007-G005Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
Purpose
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.
Section A: 31 C.F.R. § 103.11 Casino and Card Club Definitions2
Question 1: What gaming institutions are subject to the BSA casino regulatory requirements?
Answer 1: 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 a ’financial institution’ under the BSA. The definition applies to both land-based and riverboat operations licensed or authorized under the laws of a state, territory,3 or tribal jurisdiction, or under the Indian Gaming Regulatory Act.4 Tribal gaming establishments that offer slot machines, video lottery terminals, or table games,5 and that have gross annual gaming revenue in excess of $1 million are covered by the definitions. Card clubs generally are subject to the same rules as casinos, unless a different treatment for card clubs is explicitly stated in 31 C.F.R. Part 103.
Question 2: Is a tribal gaming establishment that offers only bingo and related games considered a casino for purposes of the BSA?
Answer 2: No. FinCEN has the authority under the BSA to define as ’casinos’ tribal gaming establishments that offer only bingo and related games. Nevertheless, in addressing the treatment of tribal gaming under the BSA, we have indicated that ’activities such as bingo . . . are not generally offered in casino-like settings and may create different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.’6 FinCEN does not view tribal gaming establishments that offer only traditional bingo (i.e., not contained in electronic gaming devices) and related games in non-casino settings as satisfying the definition of ’casino’ for purposes of the BSA.
However, a tribal gaming establishment that offers both bingo and slot machines or table games, for example, would satisfy the definition of ’casino,’ if gross annual gaming revenue exceeds $1 million. All gaming activity must go into the calculation of gross annual gaming revenue, including activity that standing alone would not transform an establishment into a casino. This is the same treatment that FinCEN applies to a state-licensed casino that offers poker (which is a non-house banked game) since poker and a poker room are an integral part of a casino operation.7
Question 3: Is a ’racino’ considered a gaming institution subject to the BSA?
Answer 3: The term ’racino’ has not been separately defined nor included specifically in the 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 or operation should be treated as a casino for purposes of the BSA. If state law defines or characterizes slot machine or video lottery operation at a racetrack as a ’casino, gambling casino, or gaming establishment,’ and the gross annual gaming revenues of that operation exceed the $1 million threshold, then the operation would be deemed to be a ’casino’ for purposes of the BSA and subject to all applicable requirements.8
Question 4: Would a race book or sports pool operator that has a ’nonrestricted’ Nevada gaming license be considered a casino for purposes of the BSA?
Answer 4: Yes. Operators or owners of a Nevada race book or sports pool,9 that are duly issued a ’nonrestricted’ Nevada gaming license,10 and that have gross annual gaming revenues in excess of $1 million are subject to the casino requirements under 31 C.F.R. Part 103, as well as all other applicable BSA requirements. This would include a Nevada race book or sports pool licensee that obtained a ’nonrestricted’ gaming license to operate a race book or sports pool on the property of another casino, or that operates a number of satellite race books and sports pools that are affiliated with a central site book.
Question 5: Is an establishment that offers only off-track betting on horse races considered a casino for purposes of the BSA?
Answer 5: In addressing the treatment of tribal gaming under the BSA, we have indicated that ’pari-mutuel wagering’ should receive the same treatment as bingo when determining whether an establishment satisfies the definition of ’casino.’ 11 Furthermore, Class III gaming under the Indian Gaming Regulatory Act includes off-track betting on horse races.12 In addition, in Nevada, an establishment that offers only off-track betting on horse races would need to obtain a non-restricted gaming license. In many instances, off-track betting on horse races will involve pari-mutuel wagering. However, pari-mutuel wagering also applies to sporting events. For purposes of the BSA, FinCEN views casinos to include establishments in Nevada and in tribal jurisdictions that offer only off-track betting, provided the establishments permit account wagering and provided gross annual gaming revenue exceeds $1 million.13 In many instances, off-track betting will involve accounts through which customers may conduct a variety of transactions, including wagers, deposits, withdrawals, and transfers of funds. As we recognized when addressing the treatment of tribal gaming under our rules, FinCEN has sought to apply the BSA to ’gaming establishments that provide both gaming and an array of financial services for their patrons.’14
Question 6: Are ’greyhound racing clubs’ that offer table games considered gaming institutions for purposes of the BSA?
Answer 6: If a ’greyhound racing club’15 generates gross annual gaming revenue in excess of $1 million from poker tables (which would be akin to offering card games in a card club or card room type operation), and if the gaming facility is duly licensed or authorized by a state or local government to do business as a card club, gaming club, card room, gaming room, or similar gaming establishment, it would be subject to the BSA.16 Therefore, once the $1 million in revenue threshold is exceeded for such poker tables, all gaming activity must go into the calculation of gross annual gaming revenue, including activity that standing alone would not deem an establishment a casino, such as greyhound racing at the track, simulcast for other greyhound racing tracks, simulcast for horse racing tracks, or simulcast for jai alai.
Question 7: Are horse racetracks that offer pari-mutuel or other forms of wagering only on races held at the track considered casinos for purposes of the BSA?
Answer 7: FinCEN does not view a horse racetrack that offers pari-mutuel or other forms of wagering only on races held at the track as a casino for purposes of the BSA. We believe that, under these circumstances, wagering is integral to hosting the race itself. Horse racing as an industry poses ’different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.’17
Section B: 31 C.F.R. § 103.22 Currency Transaction Reporting Requirements18
Question 8: Is a casino required to provide identification information on customers who have conducted reportable multiple currency transactions that were summarized through ’after the fact aggregation?’
Answer 8: The process of checking internal casino computer information, rating cards, general ledgers, and other books and records after the end of the gaming day to find reportable currency transactions is sometimes referred to as ’after the fact aggregation.’ After the fact aggregation of currency transactions does not relieve a casino of the requirement to file a FinCEN Form 103 Currency Transaction Report by Casinos (’CTRC’) on reportable multiple transactions containing all information required when it has the ability to obtain customer identification information through reviewing internal records in paper or electronic form or through automated data processing systems. The anti-money laundering compliance program requirement obligates a casino or card club to use all available information to determine a customer’s name, address, and Social Security number19 from any existing information system or other system of records for a reportable multiple transaction summarized through ’after the fact aggregation’ when a customer is no longer available.20 Also, for casinos or card clubs with automated data processing systems, programs for compliance with the BSA must provide for the use of these systems to aid in assuring compliance.21
Therefore, when a casino or card club cannot obtain identification information on reportable multiple transactions because a customer is no longer available, it must check its internal records or systems, including federal forms and records, which contain verified customer information. These records may include credit, deposit, or check cashing account records, or a previously filed CTRC form, IRS Form W-2G (Certain Gambling Winnings), or any other tax or other form containing such customer information. If a casino files a CTRC form lacking some customer identification information in situations described above, it would be required to file an amended CTRC with new identification information on the initial transaction if the customer returns and conducts new transactions of which a casino obtains knowledge.22
Question 9: Is a casino required to use customer currency transaction information contained in the casino’s 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 currency transactions conducted by or on behalf of the same customer on the same day, it is required to treat those multiple transactions as a single reportable transaction for purposes of determining whether currency transaction reporting requirements have been met. Therefore, the conclusions that apply to the aggregation of two or more transactions involving the insertion of bills into slot machines also would apply to the aggregation of such transactions with other categories of ’cash in’ transactions.
It is not necessary to have personally observed the transactions; knowledge can also be acquired from a casino examining the books, records, logs, computer files, etc., that contain information that the currency transactions have occurred after the gaming day is over. Although FinCEN regulations impose no requirement to examine books or records merely for purposes of aggregating transactions in currency and determining whether to file a report on FinCEN Form 103, BSA requirements other than the requirement to report transactions in currency may obligate a casino to examine computerized records. A casino must report transactions that the casino ’knows, suspects, or has reason to suspect’ are suspicious and implement procedures reasonably designed to assure the detection and proper reporting of suspicious transactions.25 For casinos with automated data processing systems, automated programs for compliance with the BSA must provide for the use of these systems to aid i
https://diarynote-jp.indered.space
OPSW 15 controls the speed value, can be set to force speed value to 00 upon purge. This prevents runaways from happening should an address be purged while a train is in motion. Slot Following refers to operation of a stolen locomotive. Internal Control Minimum Procedures (ICMP) secured compartment and there need not be any other secured compartment within the slot machine itself that in which the internal logic is to reside to satisfy this regulation. DEVICE STORAGE, MOVEMENT REPORTING AND DESTRUCTION.
*Slots Internal Controls Software
*Slots Internal Controls
*Slots Internal Controls Jobs
*Slots Internal Controls Switch
*Slots Internal Controls ComponentsIntroduction to West Virginia Slot Machine Casino Gambling in 2020
West Virginia slot machine casino gambling consists of five casinos including one casino resort and four racetracks with slot machines. Many retailers have a few video lottery terminals.
The West Virginia state legislature has two sets of minimum and maximum theoretical payout limits depending upon the location of the gaming machine. Limited return statistics are available annually.
This post continues my weekly State-By-State Slot Machine Casino Gambling Series, an online resource dedicated to guiding slot machine casino gambler to success. Now in its third year, each weekly post reviews slots gambling in a single U.S. state, territory, or federal district.Slots Internal Controls SoftwareKeep Reading … Or Watch Instead!Or … Listen Instead!
Find my podcast wherever you listen to audio!Relevant Legal Statutes on Gambling in West Virginia*
The minimum legal gambling age in West Virginia depends upon the gambling activity:
*Land-Based Casinos: 21
*Poker Rooms: 21
*Bingo: 18
*Lottery: 18
*Pari-Mutuel Wagering: 21
In 1994, West Virginia legalized video lottery terminals at their thoroughbred and greyhound racetracks. In 1999, West Virginia began allowing physical reel slot machines at licensed racetracks.
Machine restrictions at these pari-mutuel wagering facilities include approval by the local county and having only:
*Slots
*Blackjack
*Keno
*Many versions of poker
In 2001, West Virginia passed the Limited Video Lottery Act allowing bars and restaurants to have up to five video lottery terminals (VLTs) and fraternal organizations to have up to ten VLTs. The Act also restricted the state to a total of 9,000 VLTs.
*The purpose of this section is to inform the public of state gambling laws and how the laws might apply to various forms of gaming. It is not legal advice.Slot Machine Private Ownership in West Virginia
It is legal to own a slot machine privately in West Virginia.Gaming Control Board in West Virginia
The West Virginia Lottery Commission controls VLT gaming regulations. This lottery was created in 1984 by amending the Constitution of West Virginia with Article VI, Section 36.
Afterward, West Virginia legalized VLTs with subsequent amendments, acts, rules, and statutes. Each statute is available in the West Virginia Lottery’s Rules and Regulations.Casinos in West Virginia
There are four pari-mutuel racetracks and one casino resort in West Virginia, where their slot machines have 18 different games. In 2019, 1,303 commercial retailers each had between five and ten VLTs, offering eleven games.
The largest casino in West Virginia is Hollywood Casino at Charles Town Races with 2,500 slot machines. Porchville.
The second-largest casino is Mountaineer Casino Racetrack & Resort with 1,525 slot machines.Commercial Casinos in West Virginia
The four pari-mutuel racetracks with slot machines in West Virginia are:
*Hollywood Casino at Charles Town Races in Charles Town, 320 miles northeast of Charleston.
*Mardi Gras Casino & Resort in Cross Lanes, 10 miles northwest of Charleston.
*Mountaineer Casino Racetrack & Resort in New Cumberland, 35 miles north of Wheeling.
*Wheeling Island Hotel Casino Racetrack in Wheeling.
The single casino resort in West Virginia is:
*The Casino Club at The Greenbrier in White Sulphur Springs, 120 miles southeast of CharlestonTribal Casinos in West Virginia
West Virginia has no federally-recognized tribes and, therefore, no tribal casinos.Other Gambling Establishments
As an alternative to enjoying West Virginia slot machine casino gambling, consider exploring casino options in a nearby state. Bordering West Virginia is:
*North: Maryland Slots and Pennsylvania Slots
*East and South: Virginia Slots
*West: Kentucky Slots and Ohio Slots
Each of the links above will take you to my blog for that neighboring U.S. state to West Virginia.Our West Virginia Slots Facebook Group
Are you interested in sharing and learning with other slots enthusiasts in West Virginia? If so, join our West Virginia slots community on Facebook. All you’ll need is a Facebook profile to join this closed Facebook Group freely.
There, you’ll be able to privately share your slots experiences as well as chat with players about slots gambling in West Virginia. Join us!Payout Returns in West Virginia
West Virginia has two sets of theoretical payout limits including:
*Racetracks and casino resort: 80% and 99.9%
*Commercial retailers: 80% and 92% (or 95%, if approved)
Retailers must obtain individual permissions to have a greater than 92% payout. These high payout terminals must obtain Commission approval twice, including:
Written consent prior to manufacturing
Approval before applying for testing
From its 2019 Annual Report, the Commission reported the annual return statistics in West Virginia to be:
*Casino resort: 92.5%
*Racetracks: 89.6%
*Commercial Retailers: 92.1%Summary of West Virginia Slot Machine Casino Gambling in 2020
West Virginia slot machine casino gambling consists of one casino resort, four racetracks, and 1,303 retailers with VLT-style gaming machines. Retailers may have up to five VLTs if a bar or tavern, and up to ten VLTs if a fraternal organization. Up to 18 different games are available on these VLTs, including slot machine game themes.
The minimum theoretical payout is 80% for all VLTs. The maximum theoretical payout is 99.9% for casinos, but 92% for retailers. With permissions, retailers can obtain a 95% maximum theoretical payout for specific VLT machines.Annual Progress in West Virginia Slot Machine Casino Gambling
Over the last year, there has been no change in the West Virginia gaming industry.Other State-By-State Articles from Professor Slots
*Previous: Washington Slot Machine Casino Gambling
*Next: Wisconsin Slot Machine Casino Gambling
Have fun, be safe, and make good choices!
By Jon H. Friedl, Jr. Ph.D., President
Jon Friedl, LLCFIN-2007-G005Frequently Asked Questions Casino Recordkeeping, Reporting, and Compliance Program Requirements
Purpose
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.
Section A: 31 C.F.R. § 103.11 Casino and Card Club Definitions2
Question 1: What gaming institutions are subject to the BSA casino regulatory requirements?
Answer 1: 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 a ’financial institution’ under the BSA. The definition applies to both land-based and riverboat operations licensed or authorized under the laws of a state, territory,3 or tribal jurisdiction, or under the Indian Gaming Regulatory Act.4 Tribal gaming establishments that offer slot machines, video lottery terminals, or table games,5 and that have gross annual gaming revenue in excess of $1 million are covered by the definitions. Card clubs generally are subject to the same rules as casinos, unless a different treatment for card clubs is explicitly stated in 31 C.F.R. Part 103.
Question 2: Is a tribal gaming establishment that offers only bingo and related games considered a casino for purposes of the BSA?
Answer 2: No. FinCEN has the authority under the BSA to define as ’casinos’ tribal gaming establishments that offer only bingo and related games. Nevertheless, in addressing the treatment of tribal gaming under the BSA, we have indicated that ’activities such as bingo . . . are not generally offered in casino-like settings and may create different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.’6 FinCEN does not view tribal gaming establishments that offer only traditional bingo (i.e., not contained in electronic gaming devices) and related games in non-casino settings as satisfying the definition of ’casino’ for purposes of the BSA.
However, a tribal gaming establishment that offers both bingo and slot machines or table games, for example, would satisfy the definition of ’casino,’ if gross annual gaming revenue exceeds $1 million. All gaming activity must go into the calculation of gross annual gaming revenue, including activity that standing alone would not transform an establishment into a casino. This is the same treatment that FinCEN applies to a state-licensed casino that offers poker (which is a non-house banked game) since poker and a poker room are an integral part of a casino operation.7
Question 3: Is a ’racino’ considered a gaming institution subject to the BSA?
Answer 3: The term ’racino’ has not been separately defined nor included specifically in the 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 or operation should be treated as a casino for purposes of the BSA. If state law defines or characterizes slot machine or video lottery operation at a racetrack as a ’casino, gambling casino, or gaming establishment,’ and the gross annual gaming revenues of that operation exceed the $1 million threshold, then the operation would be deemed to be a ’casino’ for purposes of the BSA and subject to all applicable requirements.8
Question 4: Would a race book or sports pool operator that has a ’nonrestricted’ Nevada gaming license be considered a casino for purposes of the BSA?
Answer 4: Yes. Operators or owners of a Nevada race book or sports pool,9 that are duly issued a ’nonrestricted’ Nevada gaming license,10 and that have gross annual gaming revenues in excess of $1 million are subject to the casino requirements under 31 C.F.R. Part 103, as well as all other applicable BSA requirements. This would include a Nevada race book or sports pool licensee that obtained a ’nonrestricted’ gaming license to operate a race book or sports pool on the property of another casino, or that operates a number of satellite race books and sports pools that are affiliated with a central site book.
Question 5: Is an establishment that offers only off-track betting on horse races considered a casino for purposes of the BSA?
Answer 5: In addressing the treatment of tribal gaming under the BSA, we have indicated that ’pari-mutuel wagering’ should receive the same treatment as bingo when determining whether an establishment satisfies the definition of ’casino.’ 11 Furthermore, Class III gaming under the Indian Gaming Regulatory Act includes off-track betting on horse races.12 In addition, in Nevada, an establishment that offers only off-track betting on horse races would need to obtain a non-restricted gaming license. In many instances, off-track betting on horse races will involve pari-mutuel wagering. However, pari-mutuel wagering also applies to sporting events. For purposes of the BSA, FinCEN views casinos to include establishments in Nevada and in tribal jurisdictions that offer only off-track betting, provided the establishments permit account wagering and provided gross annual gaming revenue exceeds $1 million.13 In many instances, off-track betting will involve accounts through which customers may conduct a variety of transactions, including wagers, deposits, withdrawals, and transfers of funds. As we recognized when addressing the treatment of tribal gaming under our rules, FinCEN has sought to apply the BSA to ’gaming establishments that provide both gaming and an array of financial services for their patrons.’14
Question 6: Are ’greyhound racing clubs’ that offer table games considered gaming institutions for purposes of the BSA?
Answer 6: If a ’greyhound racing club’15 generates gross annual gaming revenue in excess of $1 million from poker tables (which would be akin to offering card games in a card club or card room type operation), and if the gaming facility is duly licensed or authorized by a state or local government to do business as a card club, gaming club, card room, gaming room, or similar gaming establishment, it would be subject to the BSA.16 Therefore, once the $1 million in revenue threshold is exceeded for such poker tables, all gaming activity must go into the calculation of gross annual gaming revenue, including activity that standing alone would not deem an establishment a casino, such as greyhound racing at the track, simulcast for other greyhound racing tracks, simulcast for horse racing tracks, or simulcast for jai alai.
Question 7: Are horse racetracks that offer pari-mutuel or other forms of wagering only on races held at the track considered casinos for purposes of the BSA?
Answer 7: FinCEN does not view a horse racetrack that offers pari-mutuel or other forms of wagering only on races held at the track as a casino for purposes of the BSA. We believe that, under these circumstances, wagering is integral to hosting the race itself. Horse racing as an industry poses ’different problems for law enforcement, tax compliance, and anti-money laundering programs than do full-scale casino operations.’17
Section B: 31 C.F.R. § 103.22 Currency Transaction Reporting Requirements18
Question 8: Is a casino required to provide identification information on customers who have conducted reportable multiple currency transactions that were summarized through ’after the fact aggregation?’
Answer 8: The process of checking internal casino computer information, rating cards, general ledgers, and other books and records after the end of the gaming day to find reportable currency transactions is sometimes referred to as ’after the fact aggregation.’ After the fact aggregation of currency transactions does not relieve a casino of the requirement to file a FinCEN Form 103 Currency Transaction Report by Casinos (’CTRC’) on reportable multiple transactions containing all information required when it has the ability to obtain customer identification information through reviewing internal records in paper or electronic form or through automated data processing systems. The anti-money laundering compliance program requirement obligates a casino or card club to use all available information to determine a customer’s name, address, and Social Security number19 from any existing information system or other system of records for a reportable multiple transaction summarized through ’after the fact aggregation’ when a customer is no longer available.20 Also, for casinos or card clubs with automated data processing systems, programs for compliance with the BSA must provide for the use of these systems to aid in assuring compliance.21
Therefore, when a casino or card club cannot obtain identification information on reportable multiple transactions because a customer is no longer available, it must check its internal records or systems, including federal forms and records, which contain verified customer information. These records may include credit, deposit, or check cashing account records, or a previously filed CTRC form, IRS Form W-2G (Certain Gambling Winnings), or any other tax or other form containing such customer information. If a casino files a CTRC form lacking some customer identification information in situations described above, it would be required to file an amended CTRC with new identification information on the initial transaction if the customer returns and conducts new transactions of which a casino obtains knowledge.22
Question 9: Is a casino required to use customer currency transaction information contained in the casino’s 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 currency transactions conducted by or on behalf of the same customer on the same day, it is required to treat those multiple transactions as a single reportable transaction for purposes of determining whether currency transaction reporting requirements have been met. Therefore, the conclusions that apply to the aggregation of two or more transactions involving the insertion of bills into slot machines also would apply to the aggregation of such transactions with other categories of ’cash in’ transactions.
It is not necessary to have personally observed the transactions; knowledge can also be acquired from a casino examining the books, records, logs, computer files, etc., that contain information that the currency transactions have occurred after the gaming day is over. Although FinCEN regulations impose no requirement to examine books or records merely for purposes of aggregating transactions in currency and determining whether to file a report on FinCEN Form 103, BSA requirements other than the requirement to report transactions in currency may obligate a casino to examine computerized records. A casino must report transactions that the casino ’knows, suspects, or has reason to suspect’ are suspicious and implement procedures reasonably designed to assure the detection and proper reporting of suspicious transactions.25 For casinos with automated data processing systems, automated programs for compliance with the BSA must provide for the use of these systems to aid i
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