Oct 26, 2016 Additionally, instructions are embedded within the discrete filing version of the FinCEN CTR and are revealed when scrolling over the relevant fields with your computer “mouse.” ADDITIONAL INFORMATION. CTRC-N INSTRUCTIONS General Instructions Who Must File. Any Nevada casino that qualifies as a 6A licensee pursuant to Nevada Gaming Commission Regulation 6A (Reg. 6A), generally casinos with greater than $10,000,000 in annual gross gaming revenue and with over $2,000,000 of table games statistical win. Certain persons are not.

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs).

Casinos are under increasing scrutiny these days for lax AML compliance.

A PDF reader is required to view PDF files. If you don't have one, click on the banner to download one. Prior to July 1, 2007, on Form 103-N, Currency Transaction Report by Casinos-Nevada (“CTRC-N”). It is possible that many of those filed after July 1, 2007, when the Nevada casinos began using Form 103, the CTRC, were attributable to their transition from Form 103-N to Form 103.

In March 2015, FinCEN imposed a $10 million penalty on Trump Taj Mahal in Atlantic City, New Jersey, for violations of the Bank Secrecy Act (BSA). In addition to this hefty civil penalty, Trump Taj Mahal has to conduct periodic external audits to examine its anti-money laundering BSA compliance program and provide those reports to FinCEN and the casino’s board of directors.

Trump Taj Mahal admitted to failure to implement and maintain an effective AML program, failure to report suspicious transactions, failure to properly file currency transaction reports and failure to keep appropriate records as required by the BSA. Trump Taj Mahal had received numerous warnings of deficiencies in previous regulatory examinations, but failed to remediate the problems. Trump Taj Mahal’s records is pretty bleak – in 1998 FinCEN assessed a $477,700 civil money penalty against Trump Taj Mahal for currency reporting violations.

In June 2015, FinCEN assessed a $75 million penalty against Hong Kong Entertainment Investments Ltd., d/b/a Tinian Dynasty Hotel & Casino, for BSA violations. Tinian Dynasty failed to develop and implement an AML program and no member of Tinian Dynasty staff was designated as a BSA officer in the casino. Tinian Dynasty also never conducted an independent test of its systems to ensure compliance, and no one was trained in BSA record keeping or in identifying, monitoring and reporting suspicious activity. The casino operated for years without AML programs in place and was more than happy to assist customers by conducting large financial transactions involving large amounts of cash. In some instances, casino employees provided detailed instructions on how patrons could conduct transactions without being reported or without attracting law enforcement scrutiny.

FinCEN officials have been warning casinos that more enforcement is coming. In fact, FinCEN wants casinos to start implementing a culture of compliance throughout the business and casino functions.

The BSA reporting system depends on suspicious activity reports (SARs). FinCEN looks to these reports to combat money laundering and other criminal activity, including organized crime, drug trafficking and terrorism. FInCEN has detailed regulatory requirements for the filing of such reports by casinos.

The number of SARs filed nationwide has increased nearly 70 percent over the last two years throughout the financial industry, and in casinos. The most common issues cited by SARs involving casinos are alternating transactions to avoid currency transaction report filing. However, SARs have also exposed patrons using casinos to conceal narcotics transactions, moving money in support of international fraud schemes, laundering real estate fraud money and transferring money for other illicit purposes.

FinCEN’s aggressive enforcement attitude towards casinos reflects a long-standing frustration with compliance and the lack of a culture of compliance. FinCEN has stated that it will take into account a casino’s historical compliance record when deciding whether to take an enforcement action or set the amount of a penalty.

Casinos that have repeat violations over multiple exams will receive heightened scrutiny and more severe penalties. FinCEN is including remediation requirements in its enforcement actions to ensure that violators do not repeat failures and compliance deficiencies. In addition, FinCEN may impose corporate monitors or require additional independent testing to meet certain requirements.

Unlike the SEC, FinCEN appears to be more comfortable with “neither admit nor deny” settlements with casinos. Given the possible impact that admissions could have in civil litigation, FinCEN is not wedded to specific admissions in order to settle cases.

FinCEN has made it clear on numerous occasions that it expects casinos to meet the same high standards set for other financial institutions regarding a culture of compliance. Fundamental to the creation and development of a strong culture of compliance, casinos must develop a risk management framework that is engrained into the day-to-day culture of the entity. The entity’s board and management must exercise oversight of the risk management plan to ensure the establishment of effective communication channels, culture change, discipline and accountability.

It appears you don't have a PDF plugin for this browser. Please use the link below to download 2019-federal-form-fincen104.pdf, and you can print it directly from your computer.

More about the Federal Form FinCEN104Other

We last updated the Currency Transaction Report in February 2020,and the latest form we have available is for tax year 2019. This means that we don't yet have the updated form for the current tax year. Please check this page regularly, as we will post the updated form as soon as it is released by the Federal Internal Revenue Service.You can print other Federal tax forms here.

eFile your Federal tax return now

eFiling is easier, faster, and safer than filling out paper tax forms. File your Federal and Federal tax returns online with TurboTax in minutes. FREE for simple returns, with discounts available for TaxFormFinder users!

File Now with TurboTax

Other Federal Other Forms:

TaxFormFinder has an additional 774 Federal income tax forms that you may need, plus all federal income tax forms.

Form Code	Form Name
Form W-4V	Voluntary Withholding Request
Form W-4	Employee's Withholding Allowance Certificate
Form 8962	Premium Tax Credit
Form 8332	Release/Revocation of Release of Claim to Exemption for Child by Custodial Parent
Form 8850	Pre-Screening Notice and Certification Request for the Work Opportunity CreditTax Credit

Form Sources:

The Internal Revenue Service usually releases income tax forms for the current tax year between October and January, although changes to some forms can come even later.We last updated Federal Form FinCEN104 from the Internal Revenue Service in February 2020.

• Original Form PDF is https://www.irs.gov/pub/irs-tege/fin104_ctr.pdf
• Federal Internal Revenue Service at http://www.irs.gov/

Historical Past-Year Versions of Federal Form FinCEN104

We have a total of seven past-year versions of Form FinCEN104 in the TaxFormFinder archives, including for the previous tax year. Download past year versions of this tax form as PDFs here:

2018 Form FinCEN104

FinCEN FORM 104 (Rev. 12-2003)

2015 Form FinCEN104

Form FinCEN 104 (Rev. 12-2003)

Casino Ctr Instructions Assembly

TaxFormFinder Disclaimer:

Casino Ctr Instructions

While we do our best to keep our list of Federal Income Tax Forms up to date and complete, we cannot be held liable for errors or omissions. Is the form on this page out-of-date or not working? Please let us know and we will fix it ASAP.