Nearly 20,000 'Suspicious Activities' Reported in Indian Gaming 2004-11


American Indian casinos filed 26 percent of all gaming suspicious activity reports (SARs) to the federal government during the years 2004 to June 30, 2011, and 16 percent of the dollar amounts allegedly involved, a new report shows.

The Financial Crimes Enforcement Network (FinCEN) a unit of the U.S. Treasury, said tribal-licensed gaming institutions (excluding Class I gaming, over which the federal government does not have jurisdiction) filed 19,090 SAR-Cs (the “C” is for “casino”) between 2004 and the first half of 2011, an average of more than 2,000 per year. Nationwide, there were some 75,000 SAR-Cs filed by gaming institutions (casinos and card clubs).

The Indian gaming institutions alleged $290 million in financial crimes, out of a nationwide total of about $1.8 billion.

FinCEN also said an unidentified tribal casino was third in the number of filings by an individual institution at 972 (the leader, a state licensed casino, filed 1,483).

New Jersey led the states in SAR-Cs during the time period, with 16,382. The dollar amounts alleged in this one state, $293.6 million, are more than the total for all Indian casinos.

Types of suspicious activity reported to FinCEN included bribery, check, debit and credit card fraud, theft, large currency exchanges, minimal gaming with large transactions, money laundering, structuring, unusual use of checks, use of multiple credit or deposit accounts, unusual wire transfers, unusual use of counter checks or markers, false or conflicting IDs, and terrorist financing.

FinCEN said “structuring” was the largest category of suspicious activity. Structuring involves “patron attempts to reduce the dollar amount received from chip redemptions, apparently to avoid a CTR-C (Currency Transaction Report by Casinos) filing.”

The report, called “Suspicious Activity Reporting in the Gaming Industry,” said “casinos often detected these (structuring) activities at the time of redemption through pit/cashier communication, cashier familiarity with the patron, or surveillance.”

“Minimal Gaming with Large Transactions” was the next specific category of suspicious activity, after “Other.”

“The types of suspicious activities reported reflected known money laundering and criminal techniques,” the report said. “As reports of these activities have increased, casinos have expanded the amount of useful information available to FinCEN and its law enforcement customers seeking to deter and detect criminal abuse of the gaming industry.”