Title 31 Anti-Money Laundering


Insights into the intent of Title 31 and information on the reporting and recordkeeping requirements for casinos.

Financial Crimes Enforcement Network (FinCEN)

FinCEN develops answers to Frequently Asked Questions  to assist in complying with the responsibilities under the Bank Secrecy Act (BSA).

FinCEN announced a final rulePDF that exempts casinos from the requirement to file CTRCs on jackpots from slot machines and video lottery terminals. The final rule also exempts reportable transactions in currency, under certain conditions, involving certain money plays and bills inserted into electronic gaming devices.

The Financial Crimes Enforcement Network (FinCEN) requires mandatory use of the BSA E-Filing System for filing Currency Transaction Reports and Suspicious Activity Reports.  FinCEN has prepared educational materials to assist entities, including tribes, with filing the Suspicious Activity Report, and preparing the required narrative.

FinCENPDF, in consultation with federal regulatory authorities, announces the release of two companion products designed to assist all types of enterprises in creating sufficiently detailed Suspicious Activity Reports. Some portions of this guide may not relate to a tribal enterprise.

The office of Indian Tribal Governments (ITG) is available to provide any necessary outreach and/or training as well as answer any questions that may arise with respect to this matter.  Tribal governments are encouraged to contact us if they require further assistance. 

Gaming Tax Law for Indian Tribal Governments, Publication 3908PDF
This publication provides tribal governments conducting or sponsoring gaming activities with updated information pertaining to Class I, Class II and Class III gaming activities.

ITG Tax Kit
Forms, publications and information frequently requested by tribal governments.

Frequently Asked Questions

Jurisdiction and Enforcement—Insights into the intent of Title 31 and the entities which have jurisdiction and enforcement responsibilities.

Reporting and Recordkeeping Requirements—Insights into the reporting requirements of Title 31, what forms to use, and the definition of a "structured" transaction.

Check Cashers—Insights into the definition of a check casher, the reporting and recordkeeping requirements for check cashers, and the recordkeeping requirements for financial institutions.

Money Orders—Insights into when money orders fall under Title 31, and the reporting and recordkeeping requirements for money orders.

Money Transmitters—Insights into money transmitters, and their reporting and recordkeeping requirements.

Casinos—Insights into when casinos are subject to Title 31, and the reporting and recordkeeping requirements for casinos.

Suspicious Activity Reporting by Casinos and Card Clubs—Suspicious activities, the Bank Secrecy Act (“BSA”), and Financial Crimes Enforcement Network (“FinCEN”) – what does this mean to my casino?

Penalties—Insights into the civil and criminal penalties that may be assessed under Title 31.

Money Service Businesses-Identification, Registration, Suspicious Activities, Penalties and Agent Lists—Insights into what are Money Services Businesses (MSB) and the requirements of being considered one.


Non-Casino Cash Transactions Over $10,000 - Form 8300
Insights into when non-casino entities are subject to Title 31, Form 8300, and the reporting and recordkeeping requirements for them.

Glossary of Terms

Insights into the words and phrases used in the frequently asked questions.