Title 31 Compliance for Casinos | April 2025 Update

Title 31 Compliance for Casinos

Introduction

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is responsible for enforcing Title 31 of the U.S. Code, which is the primary federal law that governs anti-money laundering (AML) compliance for casinos. Title 31 requires casinos to:

• Identify and verify the true identity of all customers
• Report suspicious transactions to FinCEN
• Keep records of all financial transactions

Casinos that fail to comply with Title 31 can face civil and criminal penalties.

Key Elements of Title 31 Compliance

The following are the key elements of Title 31 compliance for casinos:

• Customer identification and verification: Casinos must identify and verify the true identity of all customers, including their name, address, date of birth, and Social Security number. This information must be collected at the time of the customer’s first visit to the casino and updated as needed.
• Suspicious transaction reporting: Casinos must report any suspicious transactions to FinCEN. Suspicious transactions are those that are unusual or inconsistent with the customer’s normal activity and that may be indicative of money laundering or other financial crimes.
• Recordkeeping: Casinos must keep records of all financial transactions, including the date, amount, and purpose of the transaction. These records must be kept for a period of five years.

How to Comply with Title 31

There are a number of steps that casinos can take to comply with Title 31. These include:

• Implementing a customer identification and verification program
• Developing a suspicious transaction reporting program
• Implementing a recordkeeping program
• Training employees on Title 31 compliance

Casinos can also work with a third-party AML compliance solutions provider to help them implement and maintain their compliance program.

Benefits of Title 31 Compliance

Casinos that comply with Title 31 can benefit in a number of ways, including:

• Reducing the risk of financial crimes
• Protecting their reputation
• Complying with federal law
• Improving their customer relationships

Conclusion

Title 31 compliance is an important part of doing business for casinos. By complying with Title 31, casinos can reduce the risk of financial crimes, protect their reputation, and comply with federal law.

Customer Identification and Verification

Casinos must identify and verify the true identity of all customers, including their name, address, date of birth, and Social Security number. This information must be collected at the time of the customer’s first visit to the casino and updated as needed.

There are a number of ways that casinos can collect customer identification information. These include:

• Presenting customers with a written form to complete
• Taking a photograph of the customer’s driver’s license or other government-issued identification card
• Using a facial recognition system

Once the customer’s identification information has been collected, the casino must verify that the information is accurate. This can be done by:

• Comparing the customer’s identification information to a government-issued identification card
• Calling the customer to verify their identity
• Using a third-party verification service

Suspicious Transaction Reporting

Casinos must report any suspicious transactions to FinCEN. Suspicious transactions are those that are unusual or inconsistent with the customer’s normal activity and that may be indicative of money laundering or other financial crimes.

There are a number of factors that casinos should consider when determining whether a transaction is suspicious. These factors include:

• The amount of the transaction
• The source of the funds
• The destination of the funds
• The frequency of the transactions
• The relationship between the parties involved in the transaction

If a casino believes that a transaction is suspicious, it must file a suspicious activity report (SAR) with FinCEN. SARs can be filed electronically or on paper.

Recordkeeping

Casinos must keep records of all financial transactions, including the date, amount, and purpose of the transaction. These records must be kept for a period of five years.

The records that casinos must keep include:

• Customer identification records
• Suspicious activity reports
• Transaction records
• Cash transaction reports

Casinos must also keep records of their AML compliance program. These records include:

• Policies and procedures
• Training records
• Audit reports

Conclusion

By complying with Title 31, casinos can reduce the risk of financial crimes, protect their reputation, and comply with federal law. Casinos that are serious about AML compliance should implement a comprehensive AML compliance program that includes customer identification and verification, suspicious transaction reporting, and recordkeeping.