In the Casino
Casinos and Profiling
If one were to analyze the energy and money invested in customer profiling,
Casinos would be ranked as number one. Look at all the weapons a casino
has at its disposal: Players Club Cards, Casino Credit, attached hotel
rooms, valet parking, cameras everywhere, and then add facial recognition.
The biggest tool of deception is the Players Club Card. Most casinos
encourage regular use of these cards, by patrons, in order to accumulate
points, which give the player "free stuff." However, every time
you present this card, that event is recorded in their monstrous database.
Even if you do not present your Players Club Card when dining, purchasing
show tickets, golf, or something in a retail shop, if such a purchase
is made using a credit card, that information is captured!
Think about it. Considering the profit a casino takes in leads one to
believe they must have the most state-of-the-art database, coupled with
a tracking system to capture customer information. It's to the casinos
benefit to gather information on your interests. That way if they are
sponsoring a rodeo, they can sort the records in their database in several
ways to identify the most likely customers who might be enticed to attend
the event and play in the casino.
The reason for gathering this information is to enable the casino to
determine what it must do to get the customer to come back to its property,
gamble, and lose more money. Taking that marketing strategy, when a player
has accumulated points on a Players Card, he feels obligated not to "let
it go to waste." As a result, you have a subsequent visit. Send a
customer an offer for a free room and there is a good chance you've got
a return visitor. Throw in a free meal or two? The odds just increased.
After all, the general mindset of the typical casino patron is, "why
not take advantage of a free offer?"
In one sentence: Don't do it! Take a look at a typical application for
a credit line at a casino. After providing the casino with all that information,
it goes into a database. We all know how secure databases are! Imagine
a disgruntled employee who manages to keep a printed copy of a casino's
database of all its premium players. Names, addresses, bank account numbers!
It's an identity thief's dream!
Central Credit has provided services for the casino industry since the
late 1950s. Recently acquired by Global Cash Access, in 1998, it has increased
the services offered as well as its ability to invade an individual's
Global Cash Access is owned by Summit Partners, M&C International
and Bank of America. Given this knowledge, consider that if you have a
business relationship with any of these three co-owners, your information
is even more easily available to Global Cash Access.
Global Cash Access boasts of their identity verification system, IDNox,
in their battle against identity theft. In my opinion, identity verification
systems of this nature actually lead to more of a risk of identity theft.
The reasons: First, such systems require the patron to enter much more
personal information into a computer-based ATM or kiosk. Where do you
think that information goes? Second, you have surveillance cameras, which
are focused on these machines. Knowing the capability of these high-tech
cameras, do you really want to enter more personal information, which
can be reviewed on tape by some low-paid surveillance technician? Finally,
such systems require the patron to carry certain pieces of information
on his person. This is always a risk, especially in a crowded casino environment.
Global Cash Access unveiled their Arriva credit card, tailored specifically
for the casino industry. Rather than waiting on line or seeing a casino
credit officer, the customer can go directly to an ATM machine in the
casino to achieve the same result. While the intent is to provide lower
service and interest charges for patrons who desire cash advances on their
credit lines, it does not provide the protection against identity theft.
This product is specifically geared to increase productivity and revenue
for the casino industry by making it easier for patrons to borrow money,
while on the casino premises. The casino also benefits from the marketing
power of such a product. Since the patron can also use the card in the
casino's hotels, restaurants, showrooms, and retail shops, detailed information
is provided to the casino on your spending habits. This information is
used for marketing purposes, to give you more incentive to patronize a
casino. Sure, you can transfer points from this card to your comp account
held with a member casino, but with all these perks you are giving the
casino more and more information about yourself. Is it worth it in the
The services offered by Global Cash Access also allows a casino's marketing
department to be alerted whenever a player is withdrawing cash from one
of its machines. Imagine that - you take your cash, turn around, and there
is Mr. Smiles waiting to help you lose your money!
Casino Credit Services provides casinos with a dossier of all your recorded
casino activities that have been reported to their agency. In some casino-hotels,
when you check in, your name is run through a database, and the casino
is alerted to the amount of credit for which you can be pre-approved.
Bet you didn't know how invasive a simple process of getting a hotel room
The marketing ability derived from the information stored in the databases
of Global Cash Access is powerful: names, addresses, phone numbers, dates
of birth, social security numbers, drivers license numbers, and spending
habits, to name a few.
Cash Transaction Report (CTR)
In addition to banks and other financial institutions, federal law requires
casinos to file a report on all currency transactions in excess of US$10,000
(or equivalent in other currencies). The purpose is to fight the ongoing
battle against money laundering that is used to finance terrorist activities
and drug trafficking. Casinos have historically been targets for this
A casino is required to file a Currency Transaction Report ("CTR")
to the IRS, identifying any customer who conducts a cash transaction or
series of cash transactions totaling more than $10,000 in a gaming day.
The CTR will detail the customer's name, address, date of birth, and social
security number. If the customer is a regular player at the casino, he
most likely has a Player Card with an account number. If this is the case,
the casino should already have this information in their system. If not,
the casino employee will ask the customer for a form of government identification.
If the customer refuses to provide the requested information, he will
no longer be permitted to engage in further cash transactions. In most
cases, the customer will be barred from playing any casino games as well.
Notice how it is phrased "totaling more than $10,000 in a gaming
day"? If you go to a table game and buy $5,000 in chips, then later
in the day go to a different table and buy another $6,000 in chips, your
total buy-ins are $11,000. The casino is therefore required to identify
you, and if they do not already have the necessary information on file,
will ask you to show a government-issued identification.
Officially, they are required by federal law to identify the customer
exceeding the $10,000 mark. Therefore the casino gaming staff tracks
your cash buy-ins and will attempt to identify you early on. Some casinos
have specific thresholds where they will not allow any further buy-ins
for an unidentified player. It could be $5,000, $7,000, or any such amount.
Here is the important distinction: It is federal law to report a cash
transaction exceeding $10,000. If you attempt to cash in $10,001 in chips,
the casino cannot legally give you the cash unless they have information
(obtained from a government ID) on file. The same goes for buying in for
chips with cash at a table. To protect itself, a casino will make efforts
to identify you prior to hitting the $10,000 mark. However, this requirement
is solely dictated by internal casino procedures and not by federal law.
Keep in mind that if the casino asks for your ID and you refuse, they
will keep very close tabs on your cumulative cash transactions during
that day. They should do this because if they miss someone going over
$10,000, they are subject to hefty fines.
It is not uncommon, if you are playing at a table where you bought in
for $9,000 and then had a bad run, to ask to buy in for another $3,000.
You will be asked for your ID. If you refuse, the casino is within its
legal rights to refuse to allow that additional buy in.
A simple way to view this is:
An ID request resulting from cash exceeding $10,000 = Federal
An ID request resulting from cash less than $10,000 = Internal
We also need to address the term gaming day, which can differ among casinos.
A gaming day (or designated 24-hour period) could be from 12:00 midnight
until 11:59 p.m. in one casino, while it may be 7:00 a.m. until 6:59 a.m.
in another. Most customers will not have knowledge of what constitutes
the casino's gaming day.
When cashing out chips at the casino cage, the same rules apply. Keep
in mind that it can be perfectly legitimate to cash out different amounts
at different times and exceed $10,000. However, doing so will require
the cashier to identify you, as he must follow the law and file a CTR.
Do not under any circumstances perform multiple cash outs as a deliberate
attempt to avoid a CTR. This is a crime called structuring, and you can
be arrested. And, if you are in a casino with a spouse, relative or friend,
you legally cannot break down your chips and have that person cash out
for you. That could be considered a form of structuring.
In order to abide by the law, casinos have a legitimate reason to identify
a customer conducting cash transactions over $10,000. To protect themselves
from a slip-up, they implement specific procedures to identify a player
once a certain threshold is reached. However, that threshold is an internal
casino procedure, not the law.
If your usual gaming activities exceed $10,000 you will be subject to
the above regulations. If you keep your cash activity under $10,000, you
are not legally required to provide the casino with your personal information,
but understand that your refusal to comply with the casino's request might
prompt them to take other actions (see below).
Suspicious Activity Report (SAR)
Financial Institutions are required by federal regulations to file an
SAR when they suspect that a violation of federal criminal law or regulation
is being committed or attempted and involves the money being transacted.
Guess what? Casinos are required to comply with this regulation as well.
Given the vagueness of the requirements, anyone can be subject to such
reporting. The actual dollar amount that warrants an SAR filing is also
vague. I've heard that banks use a $5,000 benchmark, where casinos have
been known to use $3,000. Remember how a cash transaction in excess of
$10,000 requires a CTR filing? The $10,000 number can rate you both a
CTR and an SAR if someone finds you suspicious!
You are in the blind when such filings are made. The Bank Secrecy Act
forbids a person filing an SAR to inform the patron that it has been so
filed. However, there are two factors where a patron is protected by this
same Bank Secrecy Act:
- The filing institution is prohibited from disclosing to other institutions
that an SAR has been filed on a patron. In the casino business, patrons
frequently move from casino to casino while playing. A player may
even bring chips from the prior casino to cash in a second casino.
It is not uncommon for a casino to call another casino to inquire
about a suspicious patron. If this occurs, and a casino reveals to
another casino that an SAR was filed for the patron, that casino is
in violation of the Bank Secrecy Act. Quite serious!
- The filing institution is not permitted to inform law enforcement
authorities that an SAR was filed on a patron. Let's take a situation
where you are detained by casino security. Local police enter the
scene. If a casino employee informs the police that they filed an
SAR on the player, the casino is in violation of the Bank Secrecy
Financial institutions have a "better safe than sorry" mentality
on this issue. They
fall under the protection of the Safe Harbor Provision, where they are
granted immunity for any consequences of such transaction, provided they
filed an SAR.
The regulations as outlined under the Bank Secrecy Act clearly define
a currency transaction as the actual physical exchange of currency between
two parties. When you go to a casino gaming table and place $5,000 cash
down in exchange for chips, that is a physical exchange of currency. After
that initial $5,000 buy-in, you are using casino chips to play. Let's
say you win $12,000 and leave the table with a total of $17,000 in chips.
That is not an additional physical exchange of currency. It only becomes
such a defined exchange when you go to the cashier and exchange those
chips for actual cash.
Financial Crimes Enforcement Network (FinCen) of the U.S. Department
of Treasury spearheads the efforts of all the law enforcement agencies,
among others to fight the issues of money laundering. Under the governments
Code of Federal Regulations (CFR), Title 31 outlines those applicable
to the U.S. Department of Treasury. Within these regulations, we are discussing
1. 31 CFR 103.21: Reports by casinos of suspicious transactions.
2. 31 CFR 103.22: Reports of transactions in currency.
3. 31.CFR 103.28: Identification required.
Honing in on the regulation for identification required, this is where
casinos are attempting to gain the upper hand by misinforming their patrons.
The regulation clearly outlines the requirement for identification (government
ID and social security number) for the sole purpose of filing a Report
of transactions in currency. Such a report is required to be filed for
currency transactions, single or multiple, exceeding $10,000.00. In fairness
to casinos, they encounter players who engage in multiple cash exchanges
throughout a 24-hour period and it is difficult to keep track as to whether
the patron has exceeded the $10,000.00 threshold. For that purpose, most
maintain Multiple Transaction Logs, where they will either have the patron's
Player Card number, or in absence of that, a physical description of the
patron. At that point, it is not a legal requirement to obtain the patron's
official identification. The attempts made by the casino to do so are
an anticipatory effort dictated by internal procedures. The tricky part
is that if you do not wish to comply with the request, the casino may
not permit any further currency exchanges with you. Even though you may
have not approached the $10,000.00 mark, the casino can implement this
as their internal policy to protect itself.
A casino is required to file an SAR if the transaction is at least $5,000
(this may have been changed to $3,000) and the casino has knowledge of
or suspects that the currency involved in the exchange is related to an
illegal activity. This is a very dangerous area because of its vagueness,
making much subject to opinion rather than verifiable facts.