Structuring Casino-Related Transactions

BC

The practice of structuring involves conducting financial transactions in a manner that avoids triggering regulatory or legal reporting requirements. This practice is often associated with money laundering and other illicit activities, as it can be used to hide the source and destination of funds.

Casinos are particularly susceptible to this type of activity, as large sums of cash are commonly exchanged and there are numerous opportunities to conduct transactions in a manner that avoids detection. The two methods that can be used to structure casino-related transactions are:

1. Purchase of chips at multiple gaming tables: This involves buying chips at different gaming tables instead of one large transaction. By doing so, individuals can avoid triggering the Currency Transaction Report (CTR) threshold of $10,000, which requires casinos to file a report with the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury. For example, if an individual wishes to gamble with $50,000, they can purchase $10,000 worth of chips at five different tables, thereby avoiding the CTR threshold.

2. Use of third parties to conduct transactions: This method involves using intermediaries, such as friends or associates, to conduct transactions on behalf of the individual. The third party may purchase chips, gamble, or withdraw funds from ATMs on behalf of the individual, thereby avoiding detection. This method is particularly effective when the third party has no prior history of financial activity at the casino, as they are less likely to arouse suspicion.

It's important to note that both of these methods can be used for legitimate purposes as well. For example, a gambler may choose to buy chips at multiple tables to spread their bets or minimize their risk. However, in the context of anti-money laundering (AML) regulations, these methods are often viewed as red flags and can trigger additional scrutiny from regulators and law enforcement.