Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
Source of Funds • 1021.320(a)(2)(i):
• “A transaction requires reporting under the terms of this section if it is conducted or attempted by, at, or through a casino, and involves or aggregates at least $5,000 in funds or other assets, and the casino knows, suspects, or has reason to suspect that the transaction (or a pattern of transactions of which the transaction is a part): o (i) Involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity (including, without limitation, the ownership, nature, source, location, or control of such funds or assets) as part of a plan to violate or evade any Federal law or regulation or to avoid any transaction reporting requirement under Federal law or regulation.”
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Source of Funds • Source of funds o How to implement (most common) • Top XX number of players (10, 15, 25, 30, etc.) • IRS looking at roughly 25 of your top players • CTR/SAR threshold o Conduct risk assessment to determine threshold
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BlueBird, CPAs
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