The Title 31 shake-up

Jul 17, 2007 3:24 AM

By Ron Fortune

Sports bettors and other casino players are finding the new cash reporting requirements under Title 31 are putting a crimp in their gambling style.

The new federal regulations went into effect July 1 and some players are complaining the casinos have become much more intrusive in seeking personal identification and Social Security numbers.

A bettor told GamingToday that last week he tried to cash a $7,000 winning sports ticket, but the cashier wanted to scan his driver’s license and asked for a Social Security number — information the cage had not requested in the past.

When he refused to give up his driver’s license, the cashier refused to cash the ticket.

Under old Nevada Regulation 6A, casinos didn’t seek identification for transactions under $10,000.

But now, casinos are collecting identification for smaller transaction, partially because all transactions from the various sections of the casino are lumped together in determining the $10,000 threshold, which is recorded over a 24-hour period.

Some casinos have printed cards and other handouts that they give to customers in the hope of clarifying the new rules.

But those cards sometimes seem to vary in their interpretation of the new rules.

Here’s a quote from the card handed out at Station Casinos’ cages:

"The U.S. government and state of Nevada requires all Station Casino, Inc. properties to obtain your name, government-issued identification, taxpayer identification number (e.g., Social Security number) and other relevant information in order to complete certain transactions.

"Station Casinos, Inc. policy prohibits its employees from advising guests beyond this card. We appreciate your cooperation in our efforts to meet these requirements."

Now, here’s the explanation of the rule changes on Wynn Las Vegas’ Title 31 card:

"While the currency transaction reporting requirements remain generally the same, we would like you to be aware of two changes Wynn Las Vegas is required to make as a result of the regulatory changes.

"1. Patrons will be required to have their valid, current identification credential on file with Wynn Las Vegas prior to conducting any gaming transactions.

"2. Patrons will be required to have their Social Security Number, if applicable, on file with Wynn Las Vegas prior to conducting any gaming transactions."

Some casinos around town have posted signs stating that "all gaming transactions require a valid ID."

Nonetheless, there are bettors who have told GamingToday that they’ve cashed checks for $3,000 and sports tickets for $6,000 without any request for identification.

Which probably means that the casinos as well as their customers are still becoming used to the new reporting requirements.

So what’s a bettor to do? Comply and not worry about it, according to a highly-placed casino accountant who asked that his name be withheld.

The accountant said the federal reporting form, a Cash Transaction Report (CTR), reserves a space for a Social Security number. He said provide it when asked and don’t be concerned.

"The CTR goes to a computer service center operated by the IRS in Detroit. It never triggers investigations but someone who is under investigation by one of the federal agencies may have the CTRs accessed by the feds to get more information."

The worst thing, he added, is trying to "be cute" by refusing to give a Social Security number or providing a fictitious one.

"If you avoid having a CTR being filed because you have gone over $10,000 in the 24-hour period and refuse the casino’s request for ID and SSN you will be SARCed. A Suspicious Activity Report-Casinos (SARC) is prepared by the casino when it detects someone trying to structure a transaction to avoid the filing of a CTR, such as by refusing to provide ID when you are over $10,000 or if you try to spread out transactions over multiple days ”¦ or try to split your winnings and have a friend cash the chips to avoid the $10,000 threshold."

The accountant added that SARCs are reviewed by IRS agents in their Criminal Investigations division and are a much more serious issue than a CTR.

"A CTR simply means you had cash in or cash out ”¦ it doesn’t mean you had winnings," he said. "A CTR is basically a non-issue. The SARC is what is going to get you in trouble."