Training module created by:  Title 31 Testing, LLC

CTR Review (continued)

• It is against the law to provide any information related to Title 31 requirements to a customer for the purpose of evading reporting requirements.
  

• Multiple currency transactions shall be treated as a single transaction if the Casino has knowledge that they are by, or on behalf of, any one person and result in either cash-in or cash-out totaling more than $10,000 during any gaming day.
  

• FinCEN Form 103, known as a CTRC, is the FORMER document to complete and submit when a customer has currency transactions in excess of $10,000.  All CTRs are now filed using the BSA e-Filing System.
  

• CTRs must be e-filed to the IRS within 15 days.
  

• All BSA/Title 31 documentation must be retained by the Casino’s Audit staff in chronological order by gaming year for a minimum of five years.
  

Red Lake Gaming Enterprises, Inc

Title 31 Training