Table of Contents 

Introduction.........................................................................1 

Reporting Suspicious Activity...............................................3 

Examples of Actual Casino 

SARC Narratives.................................................................11 

Disclosure of SARC Reports 

and Underlying Facts..........................................................15 

For Further Information......................................................17 

December 2003 
Introduction 

Suspicious Activity Reporting Guidance for Casinos is intended to provide 

assistance specifically written for casinos. Casinos are required to report 

suspicious transactions under the Bank Secrecy Act (BSA).1

 The BSA 

Suspicious Activity Report (SAR) requirements apply to all casinos that meet the 

BSA definitions,2

 including those in Nevada and certain Indian gaming 

operations. 

This publication should be used as a supplement to the SAR form instructions, 

which can be found at www.fincen.gov. In addition, the Financial Crimes 

Enforcement Network (FinCEN), in consultation with the federal regulatory 

authorities, recently issued a SAR Guidance Package that consists of three parts:

Part I: Guidance on Preparing a Complete and Sufficient Suspicious 

Activity Report Narrative 

Provides financial institution filers with a recommended process 

of organizing and writing SAR narratives. 

Part II: The Suspicious Activity Report (SAR) Form 

A PowerPoint presentation providing general information about 

reporting requirements for the respective industries mandated to 

file SARs, as well as the subsequent use of those SARs. 

Part III: Keys to Writing a Complete & Sufficient SAR Narrative 

A PowerPoint presentation providing suggestions on how to 

enhance writing a SAR narrative. 

 1

 31 U.S.C. § 5311 et. seq. and the regulations promulgated there under.

2

 See the Bank Secrecy Act definitions at 31 U.S.C. 5312(a)(2)(x), and Department of Treasury

regulations at 31 CFR 103.11(n)(5) and (6). The term “casino” includes card clubs, see 31 

CFR 103.11(n)(6)(i), and this meaning is incorporated into this Guidance. 

1
2
Reporting Suspicious Activity

The BSA regulations3

 require a casino to file a Casino SAR (SARC) for any 

transaction conducted or attempted by, at, or through a casino, and involving or 

aggregating at least $5,000 in funds or other assets, that the casino knows, 

suspects, or has reason to suspect: 

• involves funds derived from illegal activity or is intended or conducted 

in order to hide or disguise funds or assets derived from illegal activity 

(money laundering); 

• is designed to evade the reporting or recordkeeping requirements of the 

BSA (structuring); 

• has no business or apparent lawful purpose or is not the sort in which the 

particular customer would normally be expected to engage, and the casino 

knows of no reasonable explanation for the transaction after examining 

the available facts; or 

• involves use of the casino to facilitate criminal activity. 

A casino has 30 calendar days to file a SARC after the date of initial detection of

any suspicious transaction or pattern of suspicious transactions or activities that 

are required to be reported. If the casino is unable to identify a suspect on the 

date it initially became aware of the suspicious transaction, the filer has an 

additional 30 calendar days to file, but in any circumstance, a SARC must be filed 

within 60 calendar days. 

A casino should develop and implement its SAR Program as a part of its larger 

Anti-Money Laundering (AML) Program.

4

 An effective AML Program is one 

that is developed and implemented commensurate with the risks posed by the 

products and financial services provided by the casino, and that is maintained and 

 3 31 U.S.C. § 5318(g); 31 CFR 103.21. 

4

 Casinos must develop and implement written AML programs. 31 U.S.C.

§ 5318(a)(2); 31 CFR 103.64 and 103.120(d). At a minimum, each AML program must have: 

(a) a system of internal controls reasonably designed to prevent money laundering and assure

compliance with the BSA; (b) internal or external testing for compliance with a scope and

frequency commensurate with the risks of money laundering and terrorist financing and

products and services provided; (c) training of casino personnel; (d) designation of an

individual or individuals responsible for day-to-day compliance with the BSA and the

program; and (e) procedures for using all available information to determine the name, 

address, social security number, and other information, and verification, of a person when

required, and to determine the occurrence of any transactions or patterns of transactions

required to be reported as suspicious; and (e) for casinos that have computer systems, 

automated programs to aid in assuring compliance. 

3
reasonably designed to prevent the casino from being used to facilitate money 

laundering or terrorist financing. 

Each casino should apply the same risk-based analysis of its business to create a 

process for detection, analysis and reporting of potentially suspicious activity. 

Based upon its assessment of the risks of its business, its SAR Reporting Program

may be more or less elaborate than programs of other casinos. The extent of the 

SAR Reporting Program should depend upon the characteristics of the customers 

and the casino, and the context in which the transactions occur. If the casino 

determines that an activity is suspicious, it must file a SARC. The casino, after 

investigation, may determine that the activity is not suspicious. In that case, the 

casino should document the basis for its determination that the transaction is not, 

after all, suspicious. 

SARC compliance examinations will look at the whether a casino’s written 

program is designed to address the money laundering risks of your particular 

business, whether the casino and its employees are following the program, 

whether employees are being properly trained, whether the program is being 

audited and the results of that audit, and whether the casino responds to red flags 

and other indicia that the compliance program is deficient. 

Filling out a SARC 

Completeness and accuracy are essential. Make sure all the required fields are 

filled out as fully as possible and accurately, including the correct spelling of

proper names. If a casino has a middle name or middle initial for a suspect, it 

should be included. If the casino has no identifying information about a customer 

whose transactions are suspicious, the casino should provide the best possible 

physical description of the customer in the “narrative” portion of the SARC. A 

SARC is completed when all of the available information has been entered and 

responses such as “none” or “not available” have been entered in any blank 

critical field. These responses are words, phrases or codes that inform FinCEN 

that data for that item is unavailable or not applicable, and has not been simply 

overlooked by the filer. Items are considered critical when they contain important 

information required for law enforcement investigations, such as: subject name, 

subject identifying number and address, type of suspicious activity, and a detailed 

narrative. 

The Narrative, Part VI, is critical to criminal investigators and analysts and must 

be completed. It is the casino’s opportunity to explain why it is filing the report. 

Do not merely repeat information provided in Parts I and II of the form. Instead, 

describe why the conduct of the person or the transaction itself caused the casino 

become suspicious. Be specific. Be sure to include whatever details are known 

about the transaction, e.g., the type of monetary instrument deposited (currency, 

cashier’s checks, traveler’s checks, foreign drafts or money orders), the number 

on the monetary instrument, if applicable, account numbers and the banks upon 

4
which the monetary instruments are drawn. Also identify any other financial 

institutions or foreign countries through which the transaction is routed. 

General statements such as: “possibly suspicious activity” or “attempt to structure 

$8,000” are not adequate to notify law enforcement of the precise nature of the 

suspicious activity. 

A better example would be: 

Individual described in Part I, on first visit to casino, asked if the cage

could wire proceeds of his cage deposit to his accounts number 1234

at ABC Bank in Country A, account number 5678 at DEF Bank in

Country B and account number 9101 at GHI Bank in Country C. The 

cage deposit of $175,000, in cash, was made on 4/25/2003. A CTR 

was filed for the deposit transaction and ID is on file. Records show he

drew down only $5000 before he made the request to wire the funds.

When his request was refused, he started shouting and said that all the

other casinos let him do this. Additional documentation is available

along with videotape of the incident at the cage. 

This example clearly states who was involved, what happened, why the filer 

concluded the actions of the suspect were suspicious, the amounts involved and 

indicates that the filer has backup with detailed information. Providing details 

about the amount of currency, negotiable instruments, checks, cash equivalents, 

chips or tokens involved in the transaction is important because large amounts 

may be of particular interest to investigators and law enforcement. The backup 

information may be retained in either hard copy or electronically, on magnetic 

media, digital format, or any other form of mass document storage. 

As was done in the above example, if there is additional information a casino 

believes will be helpful to investigators, it should state this in the Narrative 

Section. However, the casino should not include the backup materials with the 

SARC form when it is filed. Cancelled checks, credit reports, spreadsheets, 

photos, charts, other casino records, extra pages, etc. should not be attached to the 

SARC. Information contained on SARC forms is entered into a computer system, 

so only data that can be typed can be accepted and included in the database. Any 

backup materials are “deemed to be filed” with the SARC, and those materials 

should be retained with the casino’s copy of the SARC so that investigators or 

law enforcement officials can request and review the materials. 

If a customer engages in the same suspicious activity every time he or she comes 

to the casino, the casino should file a SARC each time the customer engages in 

the suspicious activity. Nothing in the BSA or the implementing regulations 

requires a casino to exclude a customer from gaming, even if the casino has filed 

multiple SARCs on that customer. However, depending on the circumstances, 

the casino should consider whether, in its business judgment, risk that the 

customer actually is engaged in money laundering or terrorist financing activities 

warrants exclusion of the customer from the casino. 

5
What makes a transaction suspicious? 

A casino is required to file a SARC if you “know, suspect or have reason to 

suspect “ an activity or transaction is suspicious. It is not required to have proof 

of any illegality, nor is it required to form a legal opinion. It is the responsibility 

of the appropriate governmental agencies to analyze the SARs received from all 

reporting financial institutions and to investigate possible violations of the law. 

The BSA contains a “safe harbor” providing broad protection from civil liability 

to casinos, card clubs and their employees that file SARCs or otherwise report 

suspicious activity. The safe harbor applies whether the SARC is required or 

voluntary, and also protects the filer for not disclosing the fact that a SARC has 

been filed. 

Item 26 in Part II of the form lists 16 specific types of suspicious activity. 

Because suspicious transactions may comprise more than one of the listed types 

of activities, the filer should check as many boxes as are applicable (but be sure to 

check at least one box). 

Non-Title 31 Illegal Activities

Several of the listed activities involve illegal conduct: 

• Bribery/gratuity; 

• Check fraud; 

• Credit/debit card fraud; 

• Embezzlement/theft; and 

• Misuse of position. 

The Narrative should describe the illegal conduct in detail. For example: 

On June 3, 2003 at 2:30 PM, customer described in Part I

offered $500 in $100 chips to Pit Manager Jean Smith (Pit 3) 

to alter his player rating slip to show a smaller currency 

transaction. Smith alerted Security officers who removed

customer from the table for interrogation. Gaming regulators 

were also notified. Security reports, affidavits, videotapes and

other investigative materials are available with Contact listed

on Part V of the SARC. 

Remember that a casino is not required to file a SARC for a robbery or 

burglary that has been reported to an appropriate law enforcement 

authority. 

6
Locally-Prohibited Activities

Other of the listed activities involve conduct that may be suspicious or 

prohibited in a gaming jurisdiction. For example, many jurisdictions 

prohibit an individual from establishing multiple accounts using an alias, 

nickname or other aka. Other suspicious or prohibited activities may 

include: 

• Large currency exchanges; 

• Minimal gaming with large transactions; 

• Use of multiple credit or deposit accounts; and 

• False or conflicting IDs.

Example: 

Ron Jones, customer account # 2233445, who always plays 

with credit, brought $25,000 cash in $5, $10, and $20 

denominations to the casino cage. He requested the full 

amount in $100 bills. The cage cashier, James Patel, called

for the cage supervisor, Alan Major. Major asked why Jones 

wanted to carry around so much cash since he always uses his 

credit line. Jones responded that he was a good customer of

the casino and they had no right to ask him. After consulting

with the casino manager, Jean Brody, the currency exchange

was conducted. 

Because Jones had no reasonable explanation for the large currency 

exchange of small bills, never previously used cash, and his credit records

showed that he owned a large non-cash business, the casino believes that 

the transaction may be suspicious. All cage transactions and gaming 

transactions for that visit are available with the copy of the SARC. 

Illegal Activities under Title 31

Several of the activities listed in Item 26 of Part II involve conduct that is 

prohibited under Title 31: 

• Money laundering; 

• Structuring; and 

• Terrorist financing. 

 

Money Laundering 

Money laundering is defined in 31 U.S.C. § 5340 to include the 

movement of “illicit” cash or cash equivalent proceeds into, out of, 

or through the U.S. or U.S. financial institutions. In such a case, 

the money has been generated by illegal means. 

7
Structuring 

Structuring is a violation of the BSA. It applies to conduct 

engaged in for the purpose of evading the thresholds for reporting 

or recordkeeping under the BSA. Its usual forms are the breaking 

up of a transaction into two or more smaller transactions. See 31 

U.S.C. 5324 and 103 CFR 103.11(gg). 

If a casino observes a customer engaging in multiple cash 

transactions that are divided into amounts low enough to avoid the 

filing of a CTR or other BSA recordkeeping requirements, but 

which added together, would trigger one of these requirements, 

that customer’s conduct should raise a “red flag” that the customer 

may be “structuring” his/her transactions. Examples include 

repeated wires under $3,000 that add up to over $3,000 (to evade 

the wire transfer identification/recordkeeping rule), or multiple 

cash payments or withdrawals in amounts under $10,000 that in 

the aggregate would be over $10,000 (to evade the currency 

transaction reporting requirement). Structuring can occur over 

multiple days; for example, the same person may repeatedly come

in with $9,000 in cash over a number of days. Structuring can be 

engaged in by multiple persons; for example, a group of persons 

could each wire funds of $2,990 from or to the same account. 

Remember that structuring does not depend on the illegality of the 

proceeds that are structured. Structuring itself is a crime and is 

reportable on a SAR even if the structured funds are legally 

obtained. 

In the Narrative, it is essential to describe the activity that leads the 

casino to suspect that the transaction is reportable. For example: 

Over the period from 5/20/03 to 7/31/03, Joe Smith

would buy-in with cash at the craps tables for amounts 

just under $10,000 per gaming day. He always made

hotel reservations with two other men who declined to

be rated or accept comps. They played at the same 

tables and followed his bets, also buying -in just under 

$10,000. The marketing rep, Joe Shark, asked Smith

for information about his companions but he refused to

provide any. On several occasions Smith was 

observed handing cash to the others prior to and 

during play. Based upon all these activities, we

believe that Joe Smith and his companions may be 

structuring. The SARC contact person has backup

data, including videotapes and incident reports 

completed by the marketing rep and pit personnel. 

8
Terrorist Financing 

Terrorist financing does not necessarily involve criminal proceeds. 

It is the means by which terrorist groups transfer funds around the 

world. Examples may include: 

• customer requests suspicious wire transfers to financial 

institutions in countries known as friendly to terrorism; 

• customer requests wire transfer to charity that is unfamiliar 

to the casino or appears to have links to countries that are 

friendly to terrorism; 

• fund transfer to a customer or from a customer that is 

routed through multiple financial institutions or

jurisdictions in an apparent attempt to disguise their origin; 

or 

• a customer may ask for airplane tickets, jewelry or other 

non-cash gifts (easily converted to cash) to be comped to a 

friend or to an unknown party. 

If the casino knows, suspects or has reason to suspect that a 

customer may be linked to terrorist activity against the United

States, the casino should immediately call FinCEN’s Financial 

Institutions Terrorist Hotline at the toll-free number: 1-866-556-

3974. Similarly, if any other suspected violation -- such as 

ongoing money laundering schemes -- requires immediate 

attention, the casino should notify the appropriate law enforcement 

agency. In either case, the casino must also file a SARC if the 

casino is subject to mandatory reporting. 

“Unusual Use” and “No Apparent Business Purpose” Activities

Finally, several of the activities listed in Item 26 of the SARC require 

subjective analysis of the conduct involved in the transaction to determine 

if the transaction is an “unusual use” or one that has “no apparent 

business or lawful purpose.” 

• No apparent business or lawful purpose; 

• Unusual use of negotiable instruments; 

• Unusual use of wire transfers; and 

• Unusual use of counter checks or markers 

9
Examples: 

 

A customer requests several separate casino checks for his 

cash winnings, each for amounts under $10,000. When asked 

why, he responds that he wants to put the money into different 

bank accounts. 

 

Comments: 

Here, the casino asked for a reasonable explanation and received an 

answer suggesting that the customer may be attempting to structure the 

cash. This conduct involves several of the types of suspicious activities 

listed in Item 26 – no apparent business or lawful purpose, unusual use of 

negotiable instruments, and structuring – and the casino should check each 

of these boxes on the SARC form. 

A first-time customer wires a large amount into the casino cage

from a bank in the US. After minimal gaming, he requests that 

the proceeds be wired to a joint account in a high-risk country. 

Comments: 

This conduct may involve minimal gaming with large transactions and 

unusual use of a wire transfer to a high-risk country. 

10
Examples of Actual Casino SARC Narratives 

Following are examples of actual SARC Narratives recently filed by casinos. The 

comments following each example explain why they are, or are not, sufficient. 

The Narratives have been edited to remove identifying information. 

Example #1 

Customer A, Casino account # xxxxx, approached the casino cage at

approximately 11:40 PM on 0/0/00 asking about reportable transactions.

The cashier noticed that he had two brown chips ($5000. denomination)

in his hand but didn’t cash them. He returned to cash-in $2800. in small

denomination chips. 

At 5:15 AM, a man named B came to the cage to cash in $10,000 in

brown chips but there was no verification of him having played. It was 

decided to cash him out. The pit personnel saw him walk to Customer A

and hand the cash to A. 

At 5:30 AM a woman named C came to the cage to cash in one brown

$5000 chip. Again, no verification of play was found and the customer

acted uneasy. The pit allowed the cash-out and again noticed C walk

directly to A and hand him the cash. It is the belief of the pit and the

cage, as a result, that Customer A was structuring the transaction and 

using paid agents to circumvent reporting requirements. 

Customer B-name, address, dob, id description 

Customer C-name address, dob, id description 

Comments: 

This Narrative is helpful to law enforcement and regulators because it fully 

describes the activities, provides specific identifying details about each customer 

involved in the suspicious transaction, and explains why the activities were 

suspicious. The example provides observations of the pit and cage employees 

about the actions that caused them to become suspicious. It also shows that the 

casino attempted to verify whether customers B and C had legitimate reasons for 

cashing-in large value chips. The SARC then concludes, based upon the activity 

described in the Narrative, that a violation of Title 31, specifically structuring, 

had occurred. 

Example #2 

A SARC dated 11/03/2002 was previously filed on John Doe because of

excessive wire transfers and minimal gambling activities. This 

supplemental report details recent suspect activities in which John Doe 

has engaged at Bob’s Casino with other associates, Jack Doe and Jim 

Doe, which may indicate possible money laundering. The SARC is being

filed based on numerous suspicious factors: 1. John Doe’s excessive 

wire transfer activity; 2. John Doe’s association with other players who

11
are identified by the casino as having excessive incoming wires used to 

purchase chips; 3. Pass-off chips by Jack and Jim Doe to John Doe 

which are cashed out and deposited back into John Doe’s account; and

4. Surveillance of Doe and associates which indicate minimal play by all

parties. 

Specifically, the following wire transfers and patters appeared

suspicious. Between 10/12/2002 through 1/06/2003, John Doe has 

transacted wire transfers totaling $73,850 to Jane Doe, ABC Bank, Acct. 

# 12345678. The source of these funds was cashed-in chips. During the

same time period, Jack Doe received four incoming wire transactions

totaling $30,000 from Albert Doe, Bank of Good Fortune, New York, Acct

# 76543210. Jim Doe also received $40,000 from Albert Doe, Bank of

Good Fortune, New York, Acct. # 765463210. Cash was taken from Jack 

and Jim Doe’s accounts for the purchase of chips. On five occasions as 

follows, all three subjects were observed by Bob’s Casino Security 

blackjack together at the casino: 10/12/2002, 10/20/2002, 11/02/2002,

11/03/2002, 12/17/ 2002 and 1/06/2003. Prior to the visit, Jack and Jim

Doe received wire transfers from Arnold Doe which were used to

purchase chips in increments of $6,000 to $8,000. John Doe purchased 

chips, using a smaller balance maintained on his account, that usually 

ranged between $3,000 to $4,000. The blackjack pit supervisor 

indicated each of the players did not extensively play but each took

losses when they played between $300 to $500 a time they visited. The 

blackjack supervisor has observed John Doe receiving chips from Jack

and Jim Doe during some of their visits. The casino’s surveillance of the 

subjects also confirmed observing the same type of activity between the 

customers. John Doe normally deposited between $14, 000 to $17, 000

in chips that he identified as winnings to pit clerks. Funds were usually 

wire transferred to Jane Doe on the day after John Doe visited the

casino. 

This matter has been referred to the State Gaming Commission and 

State Police. The investigation is ongoing. 

Comments: 

This Narrative provides a detailed overview of the suspicious activity and 

acknowledgement that a previous SARC was filed on the suspects. The 

conclusion of the narrative provides a clear disposition of the case in describing 

what the casino has done, and is continuing to do, in tracking the suspicious 

activities of the suspects.

Example #3 

Floorperson J. Jones went to pay a taxable jackpot on location #210,

machine # 111 for $1250. She asked the customer, (ID information in 

Part I) for ID and social security number. Jones said the customer pulled

out several social security cards, went through them, and handed one to

Jones. Jones saw a few of the cards that had the same name but did

not see if they had the same social security number. 

12
Comments: 

This Narrative is incomplete because it does not describe subsequent events. Was 

the slot jackpot paid? If paid, was it paid in cash or check? What other steps did 

the casino take regarding this customer? Was the customer known to the casino? 

Example # 4 

Subject was cashing in chips at the main cage. He had approximately 

$9000 to $11,000 in purple. He was trying to structure his cash out to

avoid being tracked by CTR. He asked how much he would have to 

cash-in in order to avoid showing ID. At this point he was getting very

agitated about having to show ID. I told him he could cash his chips in 

and during that time, I told him I was contacting Surveillance. I contacted

Security and asked if Ron would come out and ID the guest. After 

completing the transaction, Ron ID’d the guest and had a short 

conversation with him. Signed, Jack Black, Security Supervisor. 

Comments: 

This Narrative is incomplete because it does not indicate when the transaction 

occurred, does not adequately identify casino personnel involved (such as main 

cage cashier), does not indicate who “Ron” in Security. Moreover, it does not 

provide the substance of the conversation between “Ron” and the customer and 

does not indicate whether the customer was known to the casino or whether the 

“$9,000 to $11,000 in purple” was gaming proceeds. 

Example #5 

On June 27, 2003, Jane Smith came up to the third main cage and

cashed out $5000 in chips. She proceeded to hold purple chips (looked

to be about $5200) stating that she was going to keep those chips until 

later. While waiting in line, Ms. Smith was talking to another customer

about the CTR reporting process and basically telling him how to avoid a

CTR. She was explaining how the cage, table games, and slots 

compare their amounts and fill out a CTR when someone gets $10,000.

Ms. Smith told the other customer that’s why she pulls some of her chips 

back so she will not have to pay taxes. She and the other gentleman 

walked out together. 

Ms. Smith has visited our casino over the last month, usually once a

week. Her winnings were minimal until last week when on June 20, 2003

she cashed out $5000 in chips one day. She returned the following day

and cashed out an additional $5000 in chips. We have maintained a

copy of Ms. Smith’s winnings over the last month and also a copy of her 

driver’s license. Today, Ms. Smith was informed that she was barred

from our casino after she was heard instructing another customer on how 

to avoid a CTR. 

13
Comments: 

This Narrative provides specific information related to the actions by the 

customer, including dates and amounts of her transactions and her comments to 

other persons that indicate her knowledge of the BSA currency reporting 

requirements and support a conclusion that the customer was structuring her 

transactions to evade a CTR filing. 

Example #6 

It appears that John Doe may have circumvented currency reporting procedures. 

Comments: 

This Narrative is deficient because is fails to provide any information to support 

the stated conclusion. 

14
Disclosure of SARC Reports and Underlying Facts 

31 U.S.C. 5318(g)(2) requires that, if a financial institution files a SAR with a 

government agency, the financial institution may not notify any person involved 

in the transaction that the transaction has been reported. Questions have arisen 

about how a casino should respond to a civil, administrative or criminal 

subpoena; request from local regulator or similar situation. 

The casino is prohibited from complying with any subpoena requesting disclosure 

of a SARC or disclosing the fact that a SARC was filed. If you receive such a 

request, you should immediately notify the Office of Chief Counsel at FinCEN 

((703) 905-3590). The SAR regulations do not prohibit disclosure of documents, 

internal records or other information describing the transaction for which the SAR 

was filed pursuant to a validly issued subpoena or document request. A casino 

may choose to adopt a standard response to such subpoenas, but only if and so 

long as the standard response is used for all subpoena responses, whether or not 

the casino is refusing to produce a filed SARC. An example of a standard 

response could be: 

“Pursuant to 31 U.S.C. Sec. 5318(g)(2), [casino] can not confirm nor 

deny the existence of any Suspicious Activity Report for Casinos that 

might have been filed by [casino] and that would be responsive to your 

subpoena, if in fact such a report was ever filed. If such a report was 

filed, the casino would be prohibited from producing such report under 31 

U.S.C. Sec. 5318(g)(2).”

Under the regulations, SARCs may be provided to FinCEN or “an appropriate 

law enforcement or supervisory agency” regardless of whether the request is 

made through FinCEN or directly to the casino or whether the request is made by 

civil, criminal or grand jury subpoena. If a casino is unsure whether or not a 

particular agency is an appropriate requestor, the casino should call FinCEN for 

clarification.

If the casino has a separate state, local or tribal suspicious activity reporting

obligation, or an obligation to provide SARC information to state local or tribal 

regulators, the casino may provide the SARC or the information contained therein 

to those regulators pursuant to state law. For example, if state law requires a 

casino to inform the state gaming regulator that the casino has received a request 

to produce a SARC, the casino may do so. Compliance with the state, local or 

tribal gaming requirements will not relieve the casino of its responsibility to 

comply with federal BSA requirements (so in the above example, the casino also 

would have to notify FinCEN that the casino has received a request to produce a 

SAR). 

In general, a casino may not provide a copy of a SARC to another financial 

institution. However, FinCEN has been requested by casinos that have money 

15
services businesses (MSBs) on the premises, which provide services to the casino 

customers such as money transmission, check cashing, and currency exchange, 

whether the casino and the MSB could file a joint SARC on suspicious activity of

a casino customer that involves the MSB’s services. The filing of a joint SARC 

in such circumstances is permissible. In all such joint filings, only one of the 

filing institutions should be identified as the “filer” in the filer identification 

section of the SARC. The narrative of the joint SARC must include the words 

“joint filing” as well as the identifying information of the other filer or filers. 

Each filer should keep a copy of the filed SARC form for its records. In the case 

where a casino is, itself, an agent of an MSB, the casino, in its capacity as agent, 

may share with its principal any SARCs that it files as an agent of the MSB. 

In addition, a casino may share information about a transaction or a customer (but 

not the SARC form itself) with other financial institutions under the protection of

a safe harbor from civil liability pursuant to FinCEN’s rule (found at 31 CFR 

103.100) promulgated under section 314(b) of the USA PATRIOT Act, provided 

that they both file the required notices with FinCEN. The notice is available on 

the FinCEN website. Such sharing must be for the purpose of complying with the 

requirements of the BSA. 

REMEMBER: 

Deadline: A casino has 30 calendar days to file a SARC after the date of initial 

detection of any suspicious transaction or pattern of suspicious transactions or 

activities that are required to be reported. If a casino is unable to identify a 

suspect on the date it initially became aware of the suspicious transaction, it has 

an additional 30 calendar days to file, but in any circumstance must file a SARC 

within 60 calendar days. 

Liability: When a casino reports suspicious activity, the law provides protection 

from civil liability. 

The Role of the Casino: Casinos are not being asked to accuse customers of 

criminal activity – they are only required to file a SARC if they believe the 

activity is suspicious and involves or aggregates $5,000 or more. 

Urgency: If a situation seems to require immediate attention, a casino should 

contact the appropriate law enforcement authority immediately; then file a SARC. 

If a casino wishes to report suspicious transactions relating to terrorist activities, it 

should call the Financial Institutions Terrorist Hotline at 1-866-556-3974; then 

file a SARC. 

Confidentiality: It is illegal to notify any person involved in the transaction that 

a SARC has been filed. 

16
For Further Information 

BSA Forms

To download BSA forms: Visit the FinCEN website at www.fincen.gov

or IRS website at: www.irs.gov 

To order BSA forms: Call IRS Forms Distribution Center at: 1-800-

829-3676 

General Casino BSA Information 

To download: Visit the FinCEN website at www.fincen.gov 

To order: Call 1-800-386-6329 

Answers to Questions about Filing of Form

Call IRS-Detroit Computing Center Hotline at 1-800-800-2877 

Interpretation of BSA Regulations 

Call FinCEN’s Regulatory Helpline at 1-800-949-2732 

Report Terrorist Related Financial Activity 

Call Financial Institutions Hotline at 1-866-556-3974 

 

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