Training module created by:  Title 31 Testing, LLC

SARs - Review Scenarios

Scenario:

A blackjack player frequently accumulates chips during play, but does not redeem them. The customer is a frequent player who has developed close relationships with other blackjack patrons. Since he is rarely seen to cash out his chips, which type of transaction might he be conducting?

Answer:

Structuring or "Smurfing".  By structuring the cashing out of the chips through his friends/agents, always staying below $10,000 himself, he is evading and circumventing the Title 31 reporting.  

Red Lake Gaming Enterprises, Inc

Title 31 Training