Training module created by:  Title 31 Testing, LLC

Suspicious Activity Reports (SARs)

Under the suspicious activity rules, casinos must report transactions which they know, suspect, or have reason to suspect that a transaction involves funds derived from illegal activity or used for illegal purposes that are intended, whether by structuring or other means, to evade the requirements of  the Bank Secrecy Act and serve no apparent lawful purpose, and for which the casino knows of no legitimate explanation.

The most common suspicious activities are:

• Structuring the transaction to avoid CTR reporting
  

• Using agents in currency transactions to avoid going over the transaction thresholds associated with Title 31 reporting
  

• Laundering money through the machines, cage or tables to exchange money obtained illegally for the legitimate money in the casino's money circulation
  

Suspicious activities can be associated with cash, chips, slot tickets, money instruments and credit.

Red Lake Gaming Enterprises, Inc

Title 31 Training