A casino or a card club is not required to comply with rules specific to MSBs. 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 subject to the requirements applicable to casinos or card clubs, even if a casino or card club does its own check cashing. Question 2: Is a casino or a card club that cashes checks considered a money services business ('MSB')?Īnswer 2: No. 14, 2007), Question and Answer 2, concerning the treatment of bingo. 2 Joint ownership is not relevant to the determination. § 1010.100 Casino and Card Club DefinitionsQuestion 1: Are two separately licensed, but jointly-owned tribal gaming operations, one of which is a bingo hall and the other offering casino games, both treated as casinos under the BSA regulations?Īnswer 1: If a tribal government issues two separate licenses, one for a tribal gaming operation that only offers traditional bingo, and one for a tribal gaming operation that offers casino games, the former is not treated as a casino under BSA regulations, while the latter is treated as a casino under BSA regulations.

Casinos and card clubs may continue to rely on the guidance contained in FIN-2007-G005 and FIN-2009-G004, which have not been incorporated into this publication. FinCEN additionally published frequently asked questions for casinos and card clubs as FIN-2007-G005 on Novemand FIN-2009-G004 on September 30, 2009.

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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