FinCEN Form 103, Currency Transaction Report by Casinos (CTRC), must be filed by certain casinos to report each transaction in currency involving cash-in and cash-out of more than $10,000 in a gaming day (31 CFR 103.22(b)(2)).

A. Transactions in currency involving cash-in include, but are not limited to (31 CFR 103.22(b)(2)(i)):

• Purchase of chips, tokens, and plaques
• Front money deposits
• Safekeeping deposits
• Payments on any form of credit, including markers and counter checks
• Bets of currency
• Currency received by a casino for transmittal of funds through wire transfer for customer
• Purchases of a casino’s check
• Exchanges of currency for currency, including foreign currency

B. Transactions in currency involving cash-out include, but are not limited to (31 CFR 103.22(b)(2)(ii):

• Redemption of chips, tokens and plaques
• Front money withdrawals
• Safekeeping withdrawals
• Advances on any form of credit, including markers and counter checks
• Payments on bets, excluding slot and video lottery terminal jackpots
• Payments by a casino to a customer based on receipts of funds through wire transfer for credit to a customer
• Cashing of checks or other negotiable instruments
• Exchanges of currency for currency, including foreign currency
• Reimbursements for customers’ travel and entertainment expenses by the casino

C. Multiple currency transactions shall be treated as a single transaction if the casino has knowledge that they are by, or on behalf of, any person and result in either cash in or cash-out totaling more than $10,000 during any gaming day (31 CFR 103.22(c)(3)).

D. Cash-in and cash-out are to be aggregated separately.

E. A CTRC must be filed within 15 calendar days following the day the reportable transaction occurs (31 CFR 103.27(a)(1)).

Pursuant to special agreement with the Department of Treasury, Nevada casinos are subject to Nevada Gaming Commission Regulation 6A. Casinos in Nevada are required to file the following reports:

• FinCEN Form 102, Suspicious Activity Report by Casinos and Card Clubs, must be filed for any suspicious transaction that may be relevant to the possible violation of any law or regulation and involves or aggregates at least $3,000 in funds or other assets.

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