FIN-2008-G007
Recognizing Suspicious Activity - Red Flags for Casinos and Card Clubs

This guidance is intended to assist casinos and card clubs1 with the reporting of suspected money laundering, terrorist financing and related financial crimes. This guidance contains examples of circumstances or 'red flags' - based on actual reports, the observations of examiners and the experience of law enforcement - that may indicate the presence of money laundering, terrorist financing, and related financial crimes.

Timing

The majority of first-time gamblers begin on slot machines. All you really have to do is insert money and push a button. Compared to table games, slots are less intimidating for people who don’t know the proper etiquette when interacting with dealers, like placing your money on the table instead of handing it to the dealer.

Casinos that are subject to the federal Bank Secrecy Act ('BSA') have an obligation to implement anti-money laundering programs that include procedures for detecting and reporting suspicious transactions. Casinos are required to implement risk-based anti-money laundering programs that assist with the identification and reporting of suspicious transactions, including employee training and written procedures on recognizing and addressing indicia of suspicious activity and vulnerabilities that may arise in the provision of particular products and services. Recognizing Suspicious Customer Activity

Casino employees who monitor customer gaming activity or conduct transactions with customers are in a unique position to recognize transactions and activities that appear to have no legitimate purpose, are not usual for a specific player or type of players, or are not consistent with transactions involving wagering. Many casinos routinely obtain a great deal of information about their customers through deposit, credit, check cashing, player rating and slot club accounts. These accounts generally require casinos to obtain basic identification information about the accountholders and to inquire into the kinds of wagering activities in which the customer is likely to engage. Attempts to Evade BSA Reporting or Recordkeeping Requirements

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Slot Machine Timing Markers Personalized

Be alert to customers who try to keep their transactions just below the reporting or recordkeeping thresholds, such as:

  • Two or more customers each purchase chips with currency in amounts between $3,000 and $10,000, engage in minimal gaming, combine the chips (totaling in excess of $10,000), and one of them redeems the chips for a casino check.

  • A customer seeks to cash out chips, tickets or tokens in excess of $10,000, but when asked for identification for completing a CTRC, reduces the amount of chips or tokens to be cashed out to less than $10,000.

  • A customer pays off a large credit debt, such as markers or bad checks, of more than $20,000 over a short period of time (e.g., less than one week), through a series of currency transactions, none of which exceeds $10,000 in a gaming day.

  • A customer receives a race book or sports pool payout in excess of $10,000 and requests currency of less than $10,000 and the balance paid in chips. The customer then goes to the cage and redeems the remaining chips for currency in an amount that is less than the CTRC reporting threshold.

    https://golsit.netlify.app/online-casino-book-of-ra-tipps.html. the Play lines button – to the activate the lines (from 1 to 9);. the Coin button – to set the gaming currency rate (from 0,5 to2);.

  • A customer, who is a big winner, enlists another individual (who is not a partner of the customer in the gaming activity), to cash out a portion of the chips or tokens won to avoid the filing of a CTRC, IRS Form W-2G or other tax forms.

  • A customer attempts to influence, bribe, corrupt, or conspire with an employee not to file CTRCs.

Using a Cage Solely for Its Banking-Like Financial Services

Be alert to customer activity involving unusual banking-like transactions at the cage, such as:

  • A customer wires funds derived from non-gaming proceeds, to or through a bank and/or a non-bank financial institution(s) located in a country that is not his/her residence or place of business.

  • A customer appears to use a casino account primarily as a temporary repository for funds by making frequent deposits into the account and, within a short period of time (e.g., one to two days), requests money transfers of all but a token amount to domestic or foreign-based bank accounts.

Minimal Gaming Activities Without Reasonable Explanations

Be alert to customers conducting large transactions on the floor with little or no related gaming activity and without reasonable explanation, such as:

For purposes of this section, “antique slot machine” means a gambling device which is manufactured for use as a slot machine and is at least twenty-five years old. In addition to any other remedies provided by law, the following property shall be forfeited pursuant to section 13-2314 or chapter 39 of this title: 1. All machines legal Arizona: Machines 25 years or older legal: Arkansas: All machines legal California: Machines 25 years or older legal Colorado: Machines before 1984 legal Connecticut: All machines prohibited. Gambling Law US; U.S. Slot Machine Laws & Statutes by State, Gameroom Show. https://golsit.netlify.app/slot-machine-definition-arizona-law.html. Arizona statutes provide no definition of raffle, and no Arizona court has defined raffle. A raffle machine is required to follow the usual and ordinary definition of a raffle with the only difference being that it is played on a machine to qualify as a raffle machine. A second chance raffle drawing conducted after the conduct of Keno on a machine. This interpretation of the law was not agreed upon in the early 1990s when Arizona Indian tribes opened slot parlors. Then-Governor Fife Symington ordered slots shut down on reservations in 1992. Five tribes refused to shutter gaming operations and were subsequently raided.

  • A customer purchases a large amount of chips with currency at a table, engages in minimal gaming, and then redeems the chips for a casino check.

  • A customer draws casino markers (e.g., between $5,000 and $10,000) which he/she uses to purchase chips, engages in minimal or no gaming activity, and then pays off the markers in currency and subsequently redeems the chips for a casino check.

  • A customer makes a large deposit using numerous small denomination bills (e.g., $5s, $10s and $20s); and withdraws it in chips at a table game, engages in minimal gaming, and exchanges remaining chips at a cage for large denomination bills (e.g., $100), a casino check or a money transfer.

  • While reviewing computerized player rating records, an employee determines that a customer frequently purchases chips with currency between $5,000 and $10,000, engages in minimal gaming, and walks away with the chips.

  • A customer using a slot club account card inserts $2,990 of paper money (or an amount just below established thresholds) into a bill acceptor on a slot machine or video lottery terminal (e.g., contemporaneously inserting $5s, $10s and $20s), accumulating credits with minimal or no gaming activity, presses the 'cash out' button to obtain a ticket. The customer goes to three other machines and conducts the same activity for $2,990 at each machine. Then the customer redeems the tickets for large denomination bills or casino checks with different cage cashiers at different times in a gaming day.

  • A customer transfers funds to a casino for deposit into a front money account in excess of $5,000; and withdraws it in chips at a table game, engages in minimal or no gaming activity, and exchanges remaining chips at a cage for a casino check.

Unusual Transaction Characteristics or Activities

Be alert to transactions with any unusual characteristics, such as:

  • A pair of bettors frequently cover between them both sides of an even bet, such as:
    • - Betting both 'red and black' or 'odd and even' on roulette;
    • - Betting both with and against the bank in baccarat/mini-baccarat; or
    • - Betting the 'pass line' or 'come line' and the 'don't pass line' or 'don't come line' in craps; and,
    the aggregate amount of both bettors' total wagering is in excess of $5,000.
  • A customer routinely bets both sides of the same line for sporting events (i.e., betting both teams to win) and thus the amount of overall loss to the customer is minimal (known as hedging).

  • A customer requests the issuance of casino checks, each less than $3,000, which are made payable to third parties or checks without a specified payee.

  • A customer furnishes a legitimate type of identification document, in connection with the completion of a CTRC, or the opening of a deposit, credit or check cashing account, which:
    • - Does not match the customer's appearance (e.g., different age, height, eye color, sex); or
    • - Is false or altered (e.g., address changed, photograph substituted).
  • A customer presents information for the completion of CTRCs for different gaming days that contains conflicting identification information, such as:
    • - Different address or different spelling or numeration in address;
    • - Different state driver's license number; or
    • - Different social security number.
  • A customer makes large deposits or pays off large markers with multiple instruments (e.g., cashier's checks, money orders, traveler's checks, or foreign drafts) in amounts of less than $3,000.

  • A customer withdraws a large amount of funds (e.g., $30,000 or more) from a deposit account and requests that multiple casino checks be issued each of which is less than $10,000.

  • A customer arranges large money transfers out of the country which are paid for by multiple cashier's checks from different financial institutions in amounts under $10,000.

Criminal Activities

Be alert to a customer conducting illegal activity, such as:

  • A customer conducts transactions that the casino believes to be the result of some illegal activity or from an illegal source (e.g., narcotics trafficking).

  • A customer or a group of individuals forge signatures or use counterfeit business or personal checks to obtain currency, chips or tokens.

Slot Machine Timing Markers Tool

Questions or comments regarding the contents of this Guidance should be addressed to the FinCEN Regulatory Helpline at 800-949-2732.

1 See 31 U.S.C. § 5312(a)(2)(X) and 31 C.F.R. § 103.11(n)(5)(i) and (n)(6)(i). In this guidance, the term 'casino' is used to refer to casinos, card clubs and other gaming establishments that fall within the BSA and FinCEN's regulations, unless otherwise noted.

* The machine plugs right in to your wall and there is no installation required (110 volt ready)
* Factory re-furbished slot machine
* Two year warranty with each machine which covers everything but the light bulbs.
* A key for complete access to your machine
* Reset switch / Key to change the odds.
* Basic operating manual, along with unlimited technical support by phone
* We install custom made labels in each machine so that you can easily locate the reset switch, power, and volume controls without referring to the manual (refer to the picture to your left.)
* Play 1, 2, or 3 coins at once (some of the newer machines are 3 coin max bet only) If you have a question about the machine listed in this ad please email us.
* Accepts tokens only and cannot be readily changed to accept coins
* Full light and sound just like you've enjoyed in the casinos for years!
* Animated display or video screens (depending on title)
* Toll free customer support to answer any and all of your questions

Includes a fully animated LCD screen which provides hours of entertainment.

Includes an LCD Screen Minigame which can easily be played between spins!

How they are refurbished and made ready for your home:
After each machine is unloaded from the container they start off by filling in any cracks or holes that are on the outside cabinet. We fill them in with Bondo, then sand them down to be ready to paint. Once the cabinet is ready for paint, we use high quality black paint to restore your cabinet to new condition. Once the paint is dry, we have installed a 4 or 5 AMP transformer to make sure that it will be 100% safe for your home. After the transformer has been put in the machines they are tested to make sure that the transformer is properly working with the machine. Once the transformer was tested, then the machine is cleaned inside and out to restore it back to new looking condition. We check and replace all light bulbs to make sure that they are all working when they leave our warehouse. Once every corner of the machine is cleaned, it is then tested again to make sure that nothing was out of place during the detailed cleaning process. Once the machine has past another inspection by a supervisor, they are then wrapped up so that dust or dirt will not get on them. Your machine is then carefully packed in specially designed foam and boxes. Your machine has been totally refurbished and brought as close to new as possible but some normal wear might be evident due to their previous use in Real International Casinos. We only sell the machines that are the closest to being brand new as we can get them.

With each machine we offer a 2 year warranty that covers everything on the machine except the light bulbs. This warranty does not cover any damaged that comes from fire, water, lightning, dropping the machine or any other acts of nature. Please note that the warranty is to the original purchaser and is not transferable unless special arrangements are made at the time of purchase and noted at the time of purchase. Please keep your proof of purchase, the manual and the box and high density foam for each machine. These machines need to packaged properly in order to be shipped. If in the very unlikely event that your machine ever needs to come back to us, if it is not packaged correctly, the machine will be damaged and then we will not be held responsible for replacing the machine. This is why you must keep our original packing. The 2 year warranty covers all aspects of the machine excluding the light bulbs. We do not cover the bulbs but always have them for sale. These machines are very durable and meant for heavy casino use, so with proper use they should last a lifetime.

What is a Pachislo? - A Pachislo slot machine is an authentic Japanese gaming machine used in international casinos. In Japan, each casino can only use the machines for 2 years and then they have to take them out. Even though they have up to 2 years to use each machine, they do not always take the full time. This is why some machines are practically brand new when you get them. Whether they are 1 month or 5 years old, Pachislo machines are a great way to entertain your friends and family. They are high quality, backlit machines, with brilliant flashing lights, and electronic sounds. Depending on the model, some have animated LCD or LED displays or video screens. When new, these machines cost over $3500. Pachislo slot machines feature skill stop reels which is why they are also called Skill Stop Machines. You control when each reel stops, putting skill into the game. Some machines even offer interactive video screens for more exciting play.

Pachislo machines do not have pull down arms on the side of them. The reels are stopped by using the 3 buttons on the front of the machine, which is why it is called a Skill Stop machine. These machines are not meant to have pull-down arms on them. Although arms for the machine can be purchased for your machine, altering the machine in any way will void your warranty and we will not be responsible for any problems you encounter with the machine.