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Underlying facts and the report that carries them are treated differently. Section 31 CFR 1021.320(e) makes a Suspicious Activity Report, "and any information that would reveal the existence of a SAR," confidential.1 No casino and no director, officer, employee, or agent of one may disclose either.1 A casino subpoenaed or otherwise asked for one declines, citing that section and 31 U.S.C. 5318(g)(2)(A)(i), and notifies FinCEN "of any such request and the response thereto."1 A rule of construction at (e)(1)(ii) then says the prohibition is not to be construed as barring disclosure of "the underlying facts, transactions, and documents upon which a SAR is based."1 One set of events therefore supports two kinds of writing, and what separates them is whether the sentence discloses that a filing exists.
Where the line falls in a sentence
The statutory prohibition is written around revelation. Section 5318(g)(2)(A)(i) bars notifying any person involved in the transaction that it has been reported, and bars revealing "any information that would reveal that the transaction has been reported."2 A memorandum describing a customer's chip purchases discloses facts. A memorandum describing the same purchases and adding that the matter was escalated to the compliance department for filing does something else.
The rule of construction reaches further than a single office. It names disclosing the underlying facts "to another financial institution, or any director, officer, employee, or agent of a financial institution, for the preparation of a joint SAR."1 It also names sharing a SAR itself "within the casino's corporate organizational structure for purposes consistent with Title II of the Bank Secrecy Act as determined by regulation or in guidance."1 Both are conditioned on no person involved in the reported transaction being notified that it has been reported.1
Thirty days, and where the count begins
A SAR is filed "no later than 30 calendar days after the date of the initial detection by the casino of facts that may constitute a basis for filing."1 Where no suspect has been identified at initial detection, the casino may take a further 30 days.1 In no case may reporting be delayed "more than 60 calendar days after the date of such initial detection."1 For violations requiring immediate attention, the casino telephones an appropriate law enforcement authority in addition to filing on time.1
The clock runs from initial detection rather than from the transaction. The trigger is a transaction conducted or attempted by, at, or through a casino that "involves or aggregates" at least $5,000 in funds or other assets.1 The casino must know, suspect, or have reason to suspect one of four things about that transaction, "or a pattern of transactions of which the transaction is a part."1 The fourth is the shortest: that the transaction "involves use of the casino to facilitate criminal activity."1
What a currency report counts, and what the list does not close
The currency threshold works differently. Each casino reports every transaction in currency, cash in or cash out, "of more than $10,000."3 Section 1021.311 then gives nine kinds of cash-in transaction and ten kinds of cash out, each list introduced by the words "include, but are not limited to."3 Bills inserted into electronic gaming devices are on the first list; travel and complimentary expenses are on the second.3 Four categories are exempted, among them jackpots from slot machines or video lottery terminals.3
The record set is wider than the report
Paragraph 1021.410(b) lists eleven categories of record a casino must retain, and the eleventh is specific to card clubs.4 Paragraph (a) adds a separate requirement covering deposits, accounts and extensions of credit, and paragraph (c) governs records held on machine-readable media.4 Among them are "all records which are prepared or used by a casino to monitor a customer's gaming activity" and a copy of the casino's own compliance program.4 Supporting documentation for a SAR is kept five years from the filing date, must be "identified as such," and "shall be deemed to have been filed with the SAR."1
That last clause reaches a document written for another purpose. Where material is supporting documentation and is identified as such, the rule treats it as filed, whatever it was drafted for. The general rule keeps records five years and requires them to be stored so as to be "accessible within a reasonable period of time."5
Suspicion is not an editorial judgment
A compliance officer decides that a transaction is suspicious, and counsel decides that a filing is required. Neither decision is put to an editor, and nobody here forms a view on the date detection occurred. Everything a client sends us is held in confidence, and the reading we do is about disclosure rather than about suspicion.
Four questions do most of that work. Does a training slide name a filing where it means to describe conduct? Does a customer-facing letter contain a sentence that would tell its reader a report exists? Does a compliance manual use one term for one thing from beginning to end? Does a date written in one document match the same date written in another?
Appendix: The program, and what a report is filed on
The compliance program itself is a written document with a prescribed minimum. Section 1021.210(b)(1) requires each casino to develop and implement "a written program reasonably designed to assure and monitor compliance" with the Bank Secrecy Act and the regulations under it.6 Paragraph (b)(2) sets out six items the program must provide for.6 Among them are a system of internal controls and independent testing.6 For that testing, "the scope and frequency of the testing shall be commensurate with the money laundering and terrorist financing risks posed by the products and services provided by the casino."6 Another is training in the identification of unusual or suspicious transactions.6 Another is an individual or individuals to assure day-to-day compliance.6
Aggregation turns on knowledge, and knowledge is defined by reference to records. Multiple currency transactions are treated as one where the casino knows they are by or on behalf of any person.7 They must "result in either cash in or cash out totaling more than $10,000 during any gaming day."7 The two are measured against the threshold separately. The casino is deemed to have that knowledge where any sole proprietor, partner, officer, director or employee knows, acting within the scope of employment.7 Knowledge includes what comes "from examining the books, records, logs" and similar materials the casino keeps.7
Currency reports run on their own schedule. A report required by section 1021.311 is filed "within 15 days following the day on which the reportable transaction occurred."8 A copy is retained five years from the date of the report, and the report is filed with FinCEN "unless otherwise specified."8 Those reports are filed "on forms prescribed by the Secretary," and the rule adds that "all information called for in such forms shall be furnished."8
The record rules reach the form of a record as well as its content. Where an original or copy of a check or similar instrument must be retained, the casino keeps "a copy of both front and back."5 The exception is a back that is "entirely blank" or that carries only standardized printed information, a copy of which is on file.5 Where no record of a transaction is made in the ordinary course of business, "then such a record shall be prepared in writing by the financial institution."5
References
- Office of the Federal Register, Electronic Code of Federal Regulations, 31 CFR 1021.320, Reports by casinos of suspicious transactions, current as of August 2026. https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1021/subpart-C/section-1021.320 ↩
- Cornell Law School, Legal Information Institute, 31 U.S.C. 5318(g), Reporting of suspicious transactions. https://www.law.cornell.edu/uscode/text/31/5318 ↩
- Cornell Law School, Legal Information Institute, 31 CFR 1021.311, Filing obligations. https://www.law.cornell.edu/cfr/text/31/1021.311 ↩
- Office of the Federal Register, Electronic Code of Federal Regulations, 31 CFR 1021.410, Additional records to be made and retained by casinos, current as of August 2026. https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1021/subpart-D/section-1021.410 ↩
- Office of the Federal Register, Electronic Code of Federal Regulations, 31 CFR 1010.430, Nature of records and retention period, current as of August 2026. https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-D/section-1010.430 ↩
- Office of the Federal Register, Electronic Code of Federal Regulations, 31 CFR 1021.210, Anti-money laundering program requirements for casinos, current as of August 2026. https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1021/subpart-B/section-1021.210 ↩
- Cornell Law School, Legal Information Institute, 31 CFR 1021.313, Aggregation. https://www.law.cornell.edu/cfr/text/31/1021.313 ↩
- Office of the Federal Register, Electronic Code of Federal Regulations, 31 CFR 1010.306, Filing of reports, current as of August 2026. https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-C/section-1010.306 ↩
A worked example: Internal Escalation Memorandum
an internal memorandum circulated inside a casino, checked against the confidentiality rule that governs what a document may say about a filing
Section 31 CFR 1021.320(e) makes a Suspicious Activity Report, "and any information that would reveal the existence of a SAR," confidential. A rule of construction at (e)(1)(ii) provides that the prohibition is not to be construed as barring disclosure of "the underlying facts, transactions, and documents upon which a SAR is based." That is conditioned on no person involved in the reported transaction being notified that it has been reported. The statute is written the same way: 31 U.S.C. 5318(g)(2)(A)(i) bars revealing "any information that would reveal that the transaction has been reported." The facts may therefore be written down. Whether a filing exists may not be written down outside the permitted routes. Whether a transaction is suspicious and whether a report is required are decided by the casino's compliance function and its counsel. The extract below records those decisions and is reproduced unchanged in both panels.
Before
SPECIMEN, PREPARED BY EDITFAST FOR ILLUSTRATION. NOT A REAL RECORD.
Prepared for Blue Meridian Resort (fictitious), internal memorandum to floor management
EXTRACT FROM THE COMPLIANCE RECORD (reproduced unchanged in both panels)
CR-1 A report has been filed with FinCEN in respect of the activity described below. The filing itself and its existence are confidential.
CR-2 The underlying facts recorded by the compliance function: on three consecutive evenings a patron bought chips with currency in amounts of $4,200, $3,900 and $4,400, at three different tables, and cashed out by check each night.
CR-3 The compliance function has determined that this memorandum should go to floor management so that staff know what to watch for.
CR-4 Floor management is not part of the compliance function and is not a recipient permitted to be told that a filing exists.
CR-5 The patron is a person involved in the reported transactions.
MEMORANDUM: PATRON ACTIVITY, TABLES 4, 7 AND 11
Following our SAR filing last Tuesday, please note the pattern below and watch for a repeat.
On three consecutive evenings a patron bought chips with currency in amounts of $4,200, $3,900 and $4,400, at three different tables, and cashed out by check each night.
Because this has been reported, do not discuss the matter with the patron. If he asks why his play is being logged, say the account is under review.
Retain your table logs. Compliance will need them for the supporting file attached to the report.
After
SPECIMEN, PREPARED BY EDITFAST FOR ILLUSTRATION. NOT A REAL RECORD.
Prepared for Blue Meridian Resort (fictitious), internal memorandum to floor management
EXTRACT FROM THE COMPLIANCE RECORD (reproduced unchanged in both panels)
CR-1 A report has been filed with FinCEN in respect of the activity described below. The filing itself and its existence are confidential.
CR-2 The underlying facts recorded by the compliance function: on three consecutive evenings a patron bought chips with currency in amounts of $4,200, $3,900 and $4,400, at three different tables, and cashed out by check each night.
CR-3 The compliance function has determined that this memorandum should go to floor management so that staff know what to watch for.
CR-4 Floor management is not part of the compliance function and is not a recipient permitted to be told that a filing exists.
CR-5 The patron is a person involved in the reported transactions.
MEMORANDUM: PATRON ACTIVITY, TABLES 4, 7 AND 11
Please note the pattern below and watch for a repeat.
On three consecutive evenings a patron bought chips with currency in amounts of $4,200, $3,900 and $4,400, at three different tables, and cashed out by check each night.
Do not discuss this memorandum or the activity it describes with the patron. If he asks why his play is being logged, say that table logs are kept as a matter of routine.
Retain your table logs and send them to compliance on request.
[Query to compliance: the draft told floor management that logs would go into a supporting file. Under 31 CFR 1021.320(d), supporting documentation is identified as such and is deemed to have been filed with the report, so a sentence naming that destination tells its reader a report exists. The instruction to retain and send the logs is unchanged.]
What changed, and why
| Was | Now | Reason |
|---|---|---|
| Following our SAR filing last Tuesday, please note the pattern below and watch for a repeat. | Please note the pattern below and watch for a repeat. | The clause names a filing and dates it. CR-4 records that floor management is not a recipient permitted to be told a filing exists, and the confidentiality rule reaches "any information that would reveal the existence of a SAR." The instruction to watch is unaffected. |
| Because this has been reported, do not discuss the matter with the patron. If he asks why his play is being logged, say the account is under review. | Do not discuss this memorandum or the activity it describes with the patron. / If he asks why his play is being logged, say that table logs are kept as a matter of routine. | The opening clause states that a report was made. The substitute answer also mattered: CR-5 records the patron as a person involved in the reported transactions, and 31 U.S.C. 5318(g)(2)(A)(i) bars revealing information that would reveal the transaction has been reported. An account said to be under review invites the question the rule is written to prevent. |
| Retain your table logs. Compliance will need them for the supporting file attached to the report. | Retain your table logs and send them to compliance on request. / [Query to compliance: the draft told floor management that logs would go into a supporting file. Under 31 CFR 1021.320(d), supporting documentation is identified as such and is deemed to have been filed with the report, so a sentence naming that destination tells its reader a report exists. The instruction to retain and send the logs is unchanged.] | Naming the supporting file discloses the filing as plainly as naming the report. The retention instruction is what floor management needs, and it survives without the destination. |
Final specimen (PDF, 4 KB) Marked-up specimen (PDF, 7 KB)
Specimen prepared by EditFast for illustration only. Not a real document, record or filing. Any resemblance to an actual organization, person or record is unintended. Not legal, regulatory, clinical or professional advice.
Key Casinos vocabulary
- Bank Secrecy Act
- FinCEN
- Suspicious Activity Report
- Currency Transaction Report
- Initial detection
- Suspicious transaction
- Structuring
- Aggregation
- Gaming day
- Cash in
- Cash out
- Front money
- Safekeeping deposit
- Marker
- Counter check
- Money play
- Chip
- Token
- Gaming instrument
- Electronic gaming device
- Video lottery terminal
- Card club
- Cage
- Cage control log
- Multiple transaction log
- Compliance program
- Internal controls
- Independent testing
- Compliance officer
- Day-to-day compliance
- Training
- Supporting documentation
- Confidentiality of reports
- Safe harbor
- Limitation on liability
- Voluntary disclosure
- Joint filing
- Recordkeeping
- Retention period
- Machine-readable media
- Audit trail
- Nonresident alien
- Identification document
- Taxpayer identification number
- Extension of credit
- Deposit account
- Credit account
- Examination
- Tribal regulatory authority
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