What is Title 31 - Bank Secrecy Act?

Cash is King
Cash is King. Photo Courtesy (Getty Images)

Under the guise of stopping money laundering, the US Bank Secrecy Act (or Title 31) demands that every business in the United States obtain a current photo ID and social security number for any patron who spends more than $10,000 in cash during a  24-hour period.

Can you refuse to show your ID and give your social? Of course, but you won't be able to continue playing in the casino. You won't even be able to cash-in your chips.

US Bank Secrecy Act

Under the Bank Secrecy Act, casinos must report certain currency transactions to the Financial Crimes Enforcement Network, known as FinCEN, of the IRS. So, how does that affect you? Funny you should ask.

The requirements of Title 31 include tracking all cash transactions, whether paid-in (buying chips, credits, etc.) or paid-out (cashing in chips, TITO's, cash for bank documents, money orders etc.). At a threshold of $3,000 the casino is required to initiate an MTL (Multiple transaction log) that details the player's description, player account number, social security number if on file, and the time of any transactions.

The CTRC, or Currency transaction report-casino, (Crossing the threshold of $10,000 in cash transactions in a single 24-hour gaming period) that freaks people out. We are all told not to give up our social security number, so that's the rub. But, the casino has no option.

If they don't get it, they get fined. Really!.

Sheldon Adelson's Las Vegas Sands Corp. was fined $47.4 million dollars for failure to report suspicious money deposits and other transactions at the Venetian Resort Hotel and Casino.

Sure, there's some leeway on the social, as a player can fill out a W-9 form that simply lists their social security number, an actual social security card is not required to be presented.

However, the number will be checked by the casino and if it does not match the name and ID given, the player will not be allowed to gamble in the future. And, if the ID provided is not current (if it is expired), the player will not be allowed to continue gaming and must leave the premises.

The Casino's Restrictions

It does not matter how much you are winning or losing at any time in the casino. The only requirement is that you have gone over the $10,000 cash threshold in a 24-hour gaming period. And, the casino can not give you a "heads-up" that you are approaching the $10,000 limit. In fact, once you pull the cash out of your pocket and try to buy chips, if the transaction will put you over $10,000 the requirements have been met for the casino to produce a CTRC. You can't just take some of the cash back and act like it didn't happen, and neither can the casino, so don't try and make a deal. The casino can be heavily fined, and so can the Pit boss if the paperwork is not completed.

Casino Jackpots

If you hit a slot jackpot or a bonus bet jackpot on a table game you may also be required to provide a current photo ID and social security number (you can fill out a W-9 form). This will be a requirement if the jackpot is over $600 and the payoff is 300-1 or higher on table games.

These limits usually apply to poker tournaments also. At the slots, the threshold is any payout over $1199.

The casino will not be able to pay you if your photo ID is expired, even if you are a known player who has a history of excellent play at the facility. If this happens, they will give you a receipt from the cashier's cage showing your win and you will be able to redeem your payout after you bring in a non-expired photo ID.