Training module created by:  Title 31 Testing, LLC

CTR Review

• CTRs must be e-filed within 15 days of a transaction in excess of $10,000 to the IRS, using the BSA e-Filing System.
  

• A Multiple Transaction Log is maintained in each department that handles cash for recording and tracking customer information for cash/instrument transactions in excess of $3,000.
  

• Both Civil and Criminal penalties may be imposed on the Casino and or their employees for willfully violating Title 31 requirements with fines ranging from $25,000 to $100,000 and up to 10 years in prison. 
  

• Money Laundering is the disguising or concealing of illicit income in order for it to appear legitimate, or the exchange of money that was obtained illegally for legitimate money.
  

• When a Customer is reaching the $10,000 threshold in a single Gaming Day it is a violation to advise them.
  

• Structuring is process of breaking up a large sum of money into smaller sums to evade the currency reporting or record keeping requirements of Title 31.
  

Red Lake Gaming Enterprises, Inc

Title 31 Training