April 2019 - Level III Training Material

Preparing Your Property for a Title 31/AML IRS Compliance Examination

5/3/2016

Source of Funds Example SAR Scenario 1

• A credit union manager wagers approximately $192,000 in gaming devices from January 2014 through March 2014.

• What do you think? Suspicious?

Source of Funds Example SAR Scenario 2

• Male patron carrying a backpack enters Casino with female companion. The male patron enters high limit room and begins to play high limit slots. The female begins performing currency exchanges $20s for $100s, totaling roughly $6,000. The 100s are given to the male to wager in the slot machines. Total, the male has over $18,000 in bills inserted and $17,500 in jackpots.

o What do you think? Suspicious?

BlueBird, CPAs

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