Question 3: Is a 'racino' considered a gaming institution subject to the BSA?Īnswer 3: The term 'racino' has not been separately defined nor included specifically in the definition of casino for purposes of the BSA. 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.

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. 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. 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. Nevertheless, in addressing the treatment of tribal gaming under the BSA, we have indicated that 'activities such as bingo. FinCEN has the authority under the BSA to define as 'casinos' tribal gaming establishments that offer only bingo and related games. Question 2: Is a tribal gaming establishment that offers only bingo and related games considered a casino for purposes of the BSA?Īnswer 2: No.

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. 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. 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. Question 1: What gaming institutions are subject to the BSA casino regulatory requirements?Īnswer 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.

§ 103.11 Casino and Card Club Definitions 2 This document provides guidance interpreting the requirements of the Bank Secrecy Act ('BSA') regulations 1 as they apply to the casino and card club industries in the United States.

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