I 'm not sure this is really that complex of an issue. Suspicious financial
activity results if the filing of suspicious transaction reports. The feds
require institutions to file SARs using specific guidelines. It is true that
casinos are not required by the feds to file a SAR for transactions
involving less than $3,000 in a 24 hour period. On the other hand,
institutions, including casinos, MAY file a SAR involving ANY financial
transaction at any time, if they find the financial activity to be
suspicious. The example I wrote about concerning the three $900+
transactions involved a money remitter, not a casino. In fact, a SAR was
filed for those transactions. I mentioned that it involved western union
and the SAR resulted in a criminal investigation being opened on the
remitter by a federal agency that routinely investigates money laundering.
I'm sure Marissa is an excellent tax preparer but I am not sure she has
extensive knowledge of all the federal money laundering statutes and FINCEN
regulations. Many criminal investigations by the feds are generated as the
result of SARs being filed for amounts less than $3,000. The amount of
money involved in financial transactions is only one of the determining
factors in the generation of a SAR by an employee of a financial
institution. I can assure you that SARs are filed on a daily basis all over
the U.S. for aggregate amounts well below $3,000 even though in some cases
there is no U.S. Treasury Department requirement for filing, when
transactions amount to less than $3,000 in one day. These transactions
often involve "smurfing" (structuring to avoid reporting requirements) but
just as often involve other issues.
···
----- Original Message -----
From: "Jean Scott" <QueenofComps@frugalgambler.biz>
To: <vpFREE@yahoogroups.com>
Cc: "Marissa Chien" <Marissa2C@aol.com>
Sent: Sunday, March 14, 2004 2:13 PM
Subject: [vpFREE] Recent tax Thread
Concerning government paperwork - I made an incorrect statement that Marissa
caught. She wrote:
"You were incorrect in your response. As we wrote in the book, there are
different forms required to be filled out at different levels. Not all
transactions over $3,000 require paperwork at the FEDERAL level.
"In Nevada, Regulation 6a paperwork needs to be filled out on transactions
over 3k. However, no paperwork needs to be filled out for the feds until it
reaches 10k as long as there is no suspicious activity. " (Jean's note: it
is true that overzealous casino employees can go overboard on what they
consider suspicious activities but most players don't need to worry about
that unless they are playing/cashing in at very high levels.)
Marissa continued:
"Another writer was incorrect in an e-mail as there is no suspicious
activity report generated for amounts under $3k in a day for "routine"
transactions. So in the example that he cited where there were 3
transactions of $900, that is still not enough to file a SARS. Now if he
happened to do 3 transactions of $900 at 5 different locations, then it
would be different since it is over the 3k limit per day. If this person
were to consistently do 3 transactions of 900 every day, then he can be
reported for structuring which is a felony."
Hope this clears up any misunderstanding of this complex subject.
________________________________________
Jean $�ott - Go to http://www.FrugalGambler.biz
for VP software and strategy cards; "frugal" books;
and the NEW "Tax Help for the Frugal Gambler."
[Non-text portions of this message have been removed]
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