Title 31 of the Bank Secrecy Act classifies casinos with over $1 million in revenue as Non-Bank Financial Institutions (NBFIs), effectively deputizing them as federal agents in the fight against money laundering.

The Requirements

The core of this compliance regime involves filing Currency Transaction Reports (CTRs) for cash aggregates over $10,000 in a single "gaming day" and Suspicious Activity Reports (SARs) for behaviors indicating structuring (breaking transactions to evade reporting) or illicit funding.

The Venetian Settlement

The industry faced a paradigm shift following the 2013 Las Vegas Sands/Venetian settlement, where the operator paid $47.4 million for failing to report the suspicious transactions of Zhenli Ye Gon. This established that casinos could not exercise "willful blindness" toward the source of funds.

Modern Compliance

Consequently, modern casino operations utilize sophisticated Multiple Transaction Logs (MTLs) and facial recognition technology to balance the friction between intrusive federal compliance and the privacy-centric culture of high-stakes hospitality.

The Tension

Casinos walk a fine line: they must court high rollers while simultaneously watching them for suspicious behavior. The days of "no questions asked" are over, replaced by extensive documentation and federal oversight.