Category Archives: Casinos

Bill Zender Newsletter – January 2018

Bill Zender and Associates Newsletter

January 9, 2017

Dear Friends and Business Associates,

I hope everyone had an enjoyable holiday season, and is looking forward to a prosperous year in 2018.  I have planned to kick off the first quart of this year with a seminar on “Optimal Defensive Card Counting”, February 6th and 7th at the Tuscany Suites Hotel in Las Vegas, Nevada.  I usually get really “pumped” about a new seminar topic, but I’m especially charged up about this program.  Participants in this two-day session will come away with enough information and understanding to successfully defend any size casino property from attacks by the professional level card counter.

I feel the four most important points in this seminar are; (1) the myths, history, and mathematics portion which will provide the participant with an understanding of how card counting works, and why this threat is both limited to a specific educated player (successful attacks anyway), and in most cases, “revenue loss” not from the card counters, but from unnecessary prevention procedures every casino still employs.

Information gleaned during this seminar will also, (2) greatly improve your floor and surveillance staff’s ability to detect a situation of card counting, and the information on “charting” will allow any casino, regardless of its size and technical ability, to (3) confirm a suspect is counting cards (or not) with a high degree of accuracy.  Finally, the session will examine (4) different casino strategies for mitigating the effect of the card counter once that person has been confirmed as a long-term threat (notice I did not say “feel” they are counting).  For more information, please scroll down to the third section of this eBlast titled, “Scheduled Seminars and Workshops”.

Cheers to you all, and I hope everyone has a wonderful and “lucky” New Year.

Emails I have received

Following are several email questions I have received over the past month that I felt were important enough to pass along to friends/associates. 

Question:

Note: I received a text message from a casino executive who had not used a continual shuffling machine (CSM) previously.  Although I answered his text message regarding game effect of using a CSM, I felt he needed to know some more important information regarding using a CSM for the first time.  Following is my reply through email.  My thumbs are too fat for texting any quantity of information.

Answer:

It appears that you haven’t used One2Six shuffling machines (CSMs) before.  Following are some things you need to know when using an One2Six shufflers:

  • Be sure the dealers are “trained” to pick up the cards and place the cards face up in the machine.  If the dealers aren’t trained correctly, the game will slow to nothing while the floor supervisor has to remove the “upside-down” cards from the interior wheel of the machine.  I learned about this the hard way.
  • You need to stay on the dealers about maintaining an adequate game pace.  For some unknown reason, the dealers will slow their game pace on CSMs.  I think it has something to do with the removal of the deck manual shuffle or transfer time when using batch shuffling machines.
  • Don’t allow the dealers to keep several previous hands in the discard holder before placing them into the machine.  CSM machines can’t be traditionally counted; however holding out groups of cards can make it a countable game.  I would remove all discard holders from the CSM table, and force the dealer to insert each round that has been dealt immediately into the CSM.
  • This is really important: The lip of the One2Six shuffling machine is quite high as compared to most dealing shoes.  Some dealers will have a tendency to stick their thumb of their left hand (dealing hand) under the drawn hole-card.  If the dealer does this, the hole-card can be lifted and exposed accidentally to a customer sitting at third base.  Make sure all dealers remove their hole-card while the thumb of their left hand is away from the edge of the card.

 
I would imagine you know most of this, but since you haven’t used CSMs machines before (to my knowledge), I would feel bad if something happened and I hadn’t mentioned it.  Have a great holiday season my friend.
 
Question:

My question is for a player’s average bet on Ultimate Texas Holdem. Should the “play wager” be counted in a player’s average bet?

Answer:

With UTH, the average bet is the amount of the ante plus the blind, i.e., the amount of money on the layout when the first hand is dealt.  Any additional wagering is optional, and is not included.  In addition, the H/A% for UTH in most player tracking systems is usually wrong.  The game has a 2.2% H/A [applied using the ante/blind wager] if the player uses optimal computer strategy.  No one uses optimal strategy, so the true H/A% is probably around 3.5%.  Note that I didn’t include any UTH side bets.  They differ, are optional, and the average bet wagered in the side bets varys.  It’s better to leave their existence out of the player “average bet” rating equation.  BTW, the 3.5% suggested also includes a gain in H/A% from any side bet/jackpot bet H/A% influence.
 
Question:

Good afternoon Bill, what is the more effective/profitable to have a table of 6 players compared to 2 tables with 3 players in terms of hands per hour?

Answer:

Good question.  It would be better for gaining more bet decisions if more tables were open and less players were on each game.  This is a problem for brick and mortar casinos, though.  You have limited space, and the increased cost of personnel and equipment need to be considered as well.
There is some table game yield management information out there on the Internet that recommends 3 to 4 player hands per table (check Tangam Gaming http://tangamgaming.com/).  You would need to do your own cost analysis before making an educated decision whether this is better for you at your casino or not.  Personally, I would open enough games to allow for a couple of unoccupied betting circles per table average.
Once it starts to get really busy, the 3 to 4 player hands per table advantage goes out the window, and then the strategy is to open games to accommodate players.  At this point you may also consider raising minimum limits in order to maximize revenue potential.  I guess that is table game yield management in a nut shell.
 
Counting Cards Isn't Illegal - It's frowned upon!Scheduled Seminars and Workshop

Optimal Defensive Card Counting Seminar – February 6th and 7th, Las Vegas – Tuscany Suite Hotel

I will be offering a two-day seminar Optimal “Defensive” Card Counting in Blackjack.  This will be a seminar on blackjack card counting that “drills down” into all aspects of counting including the history and development of card counting techniques over the past 50 plus years.  In addition, I will spend a large portion of the time on detection and confirmation.  The one tried and true method for confirming any person is counting cards is through the process of “charting”.  Charting identifies whether or not the suspected player shows a sign of correlation between his/her wagering and the “true” count of the cards.  Unless a card counter strictly wagers into positive true counts, that counter will not be able to gain a long-term advantage over the casino. [Note: Anyone can learn how to chart].  Any participant in this seminar will definitely come away with the ability to detect if a player is counting cards, and learn the process needed to confirm a suspected player is counting on a level that places your bankroll at a long-term risk.  Some of the areas covered in this two-day seminar are:

  • Myths and history of card counting
  • Different count systems (including computers) and why these systems work.
  • Counting strategies against single and multiple deck games
  • Counting strategies for attacking side bets and variations of standard blackjack.
  • Simple methods for better detection of card counters
  • Methods for better confirmation that a person is counting.  Learn how to “chart” card counter play.
  • Mitigation of confirmed card counters: Back-off or discourage through procedural changes; what’s good, what’s bad.

Important: Requirements to attend:

  1. Presently work in the casino industry (not open to the general public).
  2. Have knowledge of multiple deck basic strategy.
  3. Have a working knowledge of the “Hi/Lo” count system (also known as “basic plus-minus”).
  4. A laptop computer (PC or MAC) compatible with Excel (used on second day to “chart”).

Because of room restrictions, I have to limit the number of participants to 40.  If you are interested, please contact me at wzender@aol.com, and I will send you a registration form.  BTW, I am now in a position to take Credit Cards. 

If you have any questions or comments, please feel free to contact me, wzender@aol.com.
 
Knowledge SharingCertificate in Gaming Leadership – University of Nevada, Reno Extended Studies and Oklahoma State University Spears School of Business – January 22-25, 2018 –  Hard Rock Casino, Tulsa, OK

I will be working with the University of Nevada Reno and Oklahoma State University to help put on the programs “Track C: Table Games Operations”.  I will be joining several other great instructors including San Manuel Surveillance Director Jessie Beaudoin and slot expert Jeff Jordan, CEO of GameCo Inc.  My schedule and Track C topics are as follows:

  • Introduction to Table Games Operations; How Casinos Make Money; Probability, Odds, Payouts – Monday, January 22nd from 10:15AM to 12:15PM.
  • Table Games Operations: Using Earning Potential as a Management Tool – Tuesday January 23rd from 8:00AM to 10:00AM.
  • Table Games Operations: Maximizing Table Games; Math & Statistics of Casino Gaming – Tuesday, January 23rd from 1:00PM to 3:00PM.
  • Optimizing Table Games Mix – Tuesday, January 23rd from 3:15PM to 5:15PM.
  • Table Games Operations: Live Game Promotion – Wednesday, January 24th from 8:00AM to 10:00AM.
  • Table Games Operations: Player Development and Database Management – Wednesday, January 24th from 10:15AM to 12:15PM.
  • Table Games Operations: The Principles of Leading Your Table Games Operation – Wednesday, January 24th from 1:00PM to 3:00PM.

For additional information, please visit the following website: https://business.okstate.edu/cepd/open-enrollment/pds/gaming-leadership.html.
 
World Game Protection Conference in Las Vegas – Bally’s – March 12th – 15th

It appears I will be presenting again this year at the WGPC.  This year I plan to speak about the problems and protection strategies with Electronic Table Games (ETGs).  Is it a slot machine or table game?  Does it take a different mindset to safely protect ETGs, or do we need to look at these games from different directions in order to block the various known and unknown avenues of attack.

ELECTRONIC TABLE GAMES: A GAME PROTECTION CHANGER – 50 minutes

Electronic Table Games (ETGs) are becoming a crowd favorite with players and are taking up an increasing amount of space on casino floors. But are they slot machines or a table games? More importantly, how do they work and how do you protect them from cheats, thieves and advantage players. If this is the ‘evolution of gaming’, it seems no one consulted with game protection professionals. In this session Bill examines the popular e-table games on the market and the relatively new concept of stadium gaming. You will hear about vulnerabilities that have been exploited in recent times and Bill’s thoughts on the best ways to protect these new-age games
For more information on the World Game Protection Conference please go to; http://www.worldgameprotection.com/
 
On the Move
I understand you can’t hit a moving target, but I still have some time available through the end of the year.  I always have time open to conduct winning player reviews.  If you have any questions, please let me know at wzender@aol.com
 
January
Northern California
Southern California
UNR/OSU Tulsa Gaming Leadership
 
February
Optimal Card Counting Seminar LV
Northern California
New Mexico
Open
 
March
Open
World Game Protection Conference
Central California
Open
 
Please let me know if I can provide one of my services for your organization.
 
 
Questions???
 
I’m always available to answer your questions. If you have any questions on gaming; don’t hesitate to contact me through email.  I answer close to a half dozen emails on gaming every day wzender@aol.com
 
Cheers and good luck.
 
Bill Zender
Bill Zender and Associates
702-423-5734

How to Deal with Issues at Online Gambling Sites

How to Deal with Issues at Online Gambling Sites

By Alice Mason

Online gambling has become a beloved way of gambling by players across the globe. The ease of betting from anywhere and anytime attracts a higher number of players. But once you start playing, it is not necessary that you would find the best online casinos only. You might face problems at some gambling sites. Sometimes the site would be wrong and sometimes you make mistakes by misunderstanding something about the games. In rare cases, there would be no one to blame for the inconvenience you face.

There is not a single gambler who has not dealt with online gambling issues. There are sites that just do not know how to treat their customers and then there are some best ones who fail to treat their players rightly. In both the cases, it is not always the site’s fault. In some cases, gamblers have to take responsibilities to solve a matter.

Below are some tips to keep in mind to avoid problems while gambling as much as possible:

– Choose to play on reputable sites only

There are two (2) reasons you should follow the advice of only going to a reputable online gambling site.  First of all, your chances of being cheated or experiencing problems are slim to none. The good reputation of any website is not just a myth or assumption. It is earned with exciting games and quality customer care services. Thus, it is pretty obvious to believe them as trustworthy casino sites.

However, problems can still occur from time to time.  The second reason for using such websites is that any website can have small to major issues but the important thing is how they deal with it. Reputable sites know how to keep their customers happy by quick and effective solutions to any problem.

– Become well-aware of the gambling rules

There are several types of rules for the different games you play online. Each game and each form of gambling has a set of relevant rules. There are rules for what should be the outcome in certain situations whether the game is abandoned or you lose your internet connection while playing your hand at an online poker.

A responsible site always provides a set of rules relating to the games provided on the website. So if the rules are there to read and the wagering requirements are mentioned on the sites, as a player, it is your responsibility to go through the terms and conditions. Many of the online casinos receive complaints related the bonuses and most of the complaints happen because the player ignores the rules and regulations.

Although most online casinos try to make the rules as clear as possible, sometimes the language or the interpretation differs that misleads the players. So it is better to read the terms and condition carefully and contact customer services about the queries and confusions you have regarding the same.

– Report your issue politely

If you experience an issue or problem, you should report it. But mind the language you use when you report it to customer support. You must be polite and respectful of the tone you use while complaining. Some of the gamblers think that being rude can get the attention faster which is never true.

The people working at customer support are human beings. Their job is indeed to help you out or assist you with your problem and not to be abused by players. Use a courteous manner while addressing them about your unpleasant experience.

In the end, it is essential to be patient and reasonable while making your point and dealing with any problems regarding online casino games. The time of response or being acknowledged also depends on the nature of the issue. Check out Norskcasinoguide.com if you want to have sound information about any of the Norwegian online casinos or games.

Comment by Michael Dalton

Always check out the casino blacklist links on the Blackjack Review Network before using any online casino site.

Use of Rolling Chips in North America

From Bill Zender’s email discussing his upcoming activities and events.
 

June 6, 2017

Dear Friends and Business Associates,

I am sorry that I haven’t kept in touch with everyone.  Between closing out my house in Las Vegas and working abroad, I didn’t have much time in which to pen my usual monthly eBlasts.  Now things have settled down, and I have some much needed breathing space.  I can start catching up with my normal routine which involves keeping everyone informed of my availability (for my benefit), and to discuss some of the issues and problems I have seen in the gaming industry over the last several months (hopefully, your benefit).

The Use of Rolling Chips in North America

Attached to June’s eBlast is a link to a report I just finished.  Over the past spring, it has come to my attention that a number of North American casino operators are searching for information on the use of non-negotiable chips in conjunction with a marketing program known in other parts of the world as “rolling chip” or “dead chip” programs.  The rolling chip/dead chip program is used extensively overseas to market and track high limit VIP baccarat customers.  A number of casinos have started similar programs domestically here in the USA and Canada.  I have also realized that the motivation to enter into a rolling chip program is stemming from requests by junket representatives, and marketers who work outside the casino operations.  In some instances, this could turn out to be a costly situation for the casinos.

These junket reps have informed the different casino marketing departments that they can provide a number of high limit baccarat players if the casino offers this non-negotiable chip form of player tracking. Unfortunately, many executives in casino operations who have either started the rolling chip programs or are strongly considering starting one, are misinformed as to the mathematics behind rolling chip “theoretical win” (T-win) projections, and are relying on the outside promoters and marketers for this information.  As one can imagine, this presents a seriously dangerous situation for the casino operators.

Because of this disturbing trend, I have compiled a report, or “white paper” if you may, that discusses several issues everyone considering entering the rolling chip/dead chip program needs to know.  The link is as follows: Rolling Chip Program in North AmericaFor some reason, a very inflated T-win percentage has been “floating” around that I’m having difficulty in pinning down the mathematics.  The higher percentage might be related to the mathematical win difference between the standard 5% Banker commission game, and the 1 to 2 Banker payoff on the “Punto Banco 6” version that is used extensively in Asia.  Regardless of the way it is calculated, the higher T-win percentage projects a higher than expected game revenue potential that subsequently helps to falsely support higher commission paybacks to either the customer or the junket rep (or both).  In many cases, domestic casinos are giving back a “lions share” of the win potential to outside interests while maintaining 100% of the gaming “risk”.  It is in the best interest of anyone entering into or considering a rolling chip program to read this report.

Marking Cards in Face-up Blackjack

A week ago I received an email from a casino executive who inquired about possible marked playing cards he had recently found on a face-up game of blackjack.  This is the second time I’ve heard about this possible scam in the last several months.  I think his question and my reply needs to be read by everyone on my eBlast list.  The question he sent me will be followed by my reply to him.

Question:
I have something that came up that has me really stumped.  While sorting cards from a six deck game at the end of the shift, one of the dealers found that a number of cards had a dimple or dent in the middle of the backs of the cards.  The cards were a number of 10s through Aces but not all.  When we went back over the play on that table, we only had one player betting black chips, but he won several thousand dollars.  Surveillance ran the player down for counting but found nothing.   My question is how would only a certain group of cards get dented like that in a face up game, and do you think we might have been hit by cheaters?  I haven’t seen anything like this before.

Reply:
There is a strong possibility you experienced a card marking team.  If the tens and aces were dented, the cheater were probably using a “top card” marking system.  If a card sitting on top of the shoe is marked (dented) the player sitting in first seat (before the shoe) will wager up to maximum bet, and if the card is not marked, the player will wager around their minimum bet.  Not all the cards are marked because it takes a long time to make sure all the “target” cards are marked.

Usually with this scam, the cheaters send in a team of players who “dent” the faces of the cards hours before the play actually goes down when the table has minimum action.  They dent the cards by hitting the faces of the cards with a chip or the tip of their fingers.  By denting the face of the playing card, one also creates a dent on the back of the card as well.  Cards marked in this manner must be read while in the window of the shoe when glare from overhead lighting reflects off the dent or bend.  After several shoes (and hours of play), the card marking team leaves the game.

As I mentioned previously, hours later the cheaters return with their “big player”.  They approach management and request a higher limit (sometimes).  Then they either get a private game for the big player, or have him sit in the first seat position in order to always receive the first card (top card) of the shoe.  A second cheater either stands or sits at the table around 5th/6th position to read the top card of the shoe.  When the top card is dented (marked), he signals the big player to place a maximum bet.  This gives the cheaters an approximate 20% edge on that wager.  If the team marking the cards is able to mark 70% of the tens and aces, a marked card will appear as the top card prior to the next hand about 25% of the time.

If you still have the video of the black chip customer’s play, see if there is a correlation between his increase in wager size, and the appearance of a ten or ace as his first card.  If so, then you need to go back over the entire day to see if you can spot the cheaters who marked the game.  You may be able to get enough video evidence to take it to the authorities.  If you have any other questions, please let me know.  Good luck with your review.

Unfortunately, I never heard back from this individual so I don’t know whether or not his surveillance personnel found anything suspicious.   Some executives believe that marking cards in a face-up game is impossible.  This is not true.  Although the act of hitting the face-up card in plain sight is obvious, these teams train to make the move look like a show of excitement, or pointing out a “lucky” card to their friend.  Here is more information on the scam setup:

First, the cheaters must find a table where the overhead light shines down and reflects off the top card of the shoe.

Second, the cheaters have to mark up the cards using a highly overt action of touching the face of the cards as they lay on the table.  This motion is usually done at the moment the dealer starts his/her bet settlement process.  The card markers will sit in the last two positions on the table and will usually control two to three hands.  The cheaters have to mark the cards without drawing suspicion to their intentions so they may use several different players over a several hour period.

Third, hours later they will confirm the marked cards are still on the game, and if so, have their “big player” buy-in and play the first hand positon.

I hope the information in this email, reply, and follow up comments gives you better insight into protecting your blackjack games.

Seminars and Workshop
As of today, I have no public seminars or workshops planned.  Since I do have some open time this summer and early fall, I may look to holding a Game Protection or Table Games Management class in different areas of the country outside of Las Vegas.  Please watch for future eBlast to find out what seminars, dates, and locations will be available.

On the Move
The dog days of summer are upon me.  Right now I’m almost filled for June, but have a couple of weeks in July, and the most part of August open.  If you have any questions, let me know wzender@aol.com.

June
Maryland
Washington DC
Northern California

July
Las Vegas BOD Meeting
Northern California

August
Northern California
Las Vegas BOD Meeting

Usually, I’m pretty much booked two months in advance.  As you see I have a bit of time open throughout the summer.  Please let me know if I can provide one of my services for your organization.

Questions???

I’m always available to answer your questions. If you have any questions on gaming; don’t hesitate in contacting me through email.  I answer close to a half dozen email on gaming every day wzender@aol.com

Cheers and good luck.

Bill Zender
Bill Zender and Associates
702-423-5734

 
Copyright © 2017 Bill Zender and Associates, All rights reserved.

Sydney Australia’s Star City Casino

Spent an afternoon at Sydney Australia’s Star City Casino this week. 

This is a huge casino with lots of blackjack tables.  However, they are not worth playing as they all use automatic shufflers.  Minimum bets that I saw started at $20 Australian which is about $15 US.  I did not check the high-pit areas which may or may not have regularly dealt blackjack. 

They also have a large poker room which I played a few hours in.  Unfortunately, their rake is awful.  I played in a small  2/3 No Limit Holdem game where there is a time rake AND and regular pot rake.  Charge is $5 / hour plus 10% up to $10 rake.  What was interesting is the dealer uses a single deck plastic box to deal the cards from.  I was told the dealer can deal faster and have both hands free at all times.  I left with a win for the session.

I also played for 30 minutes at the craps table and had another small session win.  Interesting to note that the don’t pass/come bars deuces.  In the USA, the don’t pass/come  bars 12.  No difference in the odds.

My Wife and I spent 6 days in Sydney and we also took a 10 day Celebrity Solstice cruise around New Zealand.    Ironically, the blackjack games on the cruise ship were better then the games in Sydney.  Of course, the cruise ship has their token single deck game with 6:5 rules, but their shoe games were decent: $10/$25 min tables, 8DK, double any, H17, with 1.5 – 2 decks cut off.  Occasionally, a dealer would cut off only 1 deck.

Michael Dalton

PS – Here is a photo of the single-deck shoe that poker dealers use in the Sydney, Australia poker room:

Single Deck Shoe

Casinos As Spies For The Federal Government

The following notice has not been
approved by any government official.
(In fact, some of them would probably be
unhappy to see this warning published.)

WARNING TO ALL CASINO PATRONS
By  Professor I. Nelson Rose

If you win big, are a high roller, or do anything that a casino or the government regards as suspicious, you will be reported to the U.S. Treasury Department’s Financial Crimes Enforcement Network, commonly known as FinCEN. The information will be made available to the IRS and your local law enforcement agency. Expect your taxes to be audited. If you are ever involved in a messy lawsuit, your opponent may be able to obtain some of this information by subpoena, to show, for example, how much cash you used for gambling. The casino will not always tell you when it files these reports; in fact, under some circumstances, it is not allowed to let you know that you have been reported to FinCEN.

Scary, isn’t it?

All businesses are supposed to report cash transactions over $10,000. But only “financial institutions” are required to file detailed reports and have compliance programs in place to make sure the reports get filed. And only “financial institutions” have to report “suspicious activities” involving more than $3,000 to FinCEN.

It may come as a surprise to most players and even executives in the gaming industry that large casinos and card clubs have been defined as “financial institutions.”

It will certainly be a shock to most players to learn that they may be the subject of secret reports filed by casinos with the federal government.

All casinos and card clubs with gross annual gaming revenues in excess of $1 million must file Currency Transactions Reports (CTRs) with the federal government every time a player has a cash transaction of more than $10,000. This includes players using currency to buy chips, deposit front money, pay off markers, make large wagers or collect large winning bets.

The last is particularly interesting, because the original purpose of CTRs was to track crooks who were using casinos for money laundering, like a drug dealer who bought gaming chips with $25,000 in small bills, made a few token bets, and then asked for a cashier’s check for his remaining chips.

In the mid-1980s Nevada officials, including its then-powerful Republican senators, convinced the federal government that there was no need for casinos to file CTRs when the cash was paid by casinos. Nevada enacted Regulation 6A, which required casinos to file CTRs only with the state, and only for transactions that might involve dirty money, like cash buy-ins or marker payments.

But Nevada gaming officials, apparently at the request of the federal government, changed the rules in 1997. All currency transactions of more than $10,000, even slot jackpots paid out in cash, now have to be reported. And today CTRs are filed with the IRS, not with the state.

The U.S. Congress, which is supposedly the body that actually makes the laws, had established complicated rules for withholding taxes of gambling winnings, but only under special circumstances. For example, a sports book has to withhold 28 percent of the amount won, but only if it is more than $5,000 and at least 300 times as large as the amount bet.

For years the IRS has gone further by requiring casinos to report big wins at bingo, slot machines and keno, even though no money was withheld for taxes.

Today, a CTR must be filed on every patron who cashes out for more than $10,000 in currency — no matter what the game and even if the player has lost money gambling.

The regulations also used to require that casinos obtain identification from the player before filing a CTR.

Today, a casino does not have to ask for a player’s i.d. if it already has the patron’s name, address and similar information. This eases the casinos’ workload and prevents disruptions. But it also means high-rollers do not have to be told when the casino files CTRs with the IRS.

The reason for the changes is simple: The Treasury Department has admitted that one of its primary goals is to go after untaxed cash transactions that have nothing to do with money laundering.

But Treasury still wants to catch drug dealers. So, it has taken the next step: Suspicious Activity Reports – Casinos or SARCs, to be filed with FinCEN.

As this is being written, only Nevada casinos have to file SARCs, although FinCEN intends to require all casinos and card clubs to report suspicious activities.

What exactly is a suspicious activity?

The amount does not have to be more than $10,000; a total of $3,000 or less can trigger a report. Nor does it have to involve any currency.

FinCEN likes to say the standard is know your patron. But the actual regulation is more vague, including phrases like a casino employee has reason to suspect that the transaction has no business or apparent lawful purpose.

Casinos face large fines if they fail to report suspicious transactions, and they cannot be sued for filing SARCs when players were doing nothing wrong. So, when in doubt, casinos will err on the side of filing reports on their patrons.

It is against the law for a casino to tell a player that it has reported his suspicious activity to FinCEN.

This might catch more crooks. But it is hard to picture casino executives as secret police.

Professor Rose can be reached at his Web Site:
GamblingAndTheLaw.com

#66 ©2000, all rights reserved worldwide. Gambling and the Law™ is a registered trademark of Professor I. Nelson Rose, Whittier Law School, Costa Mesa, CA.