Treasury’s Financial Crimes Enforcement Network (FinCEN) is ramping up its enforcement of Title 31, the portion of the Bank Secrecy act (BSA) that applies to casinos and card clubs. And unlike a bank, casinos are not legally required to collect a great deal of personal information from their customers before exchanging large sums of money.įor these and many other reasons, the U.S. Furthermore, a casino’s customers are often one-time visitors and people who move from state to state. Gaming is still largely a cash business, after all, and it’s not unusual for a customer to exchange thousands of dollars in a single visit. Among non-bank financial institutions, casinos top the list of businesses that federal regulators are scrutinizing for evidence of money laundering - and it’s not hard to see why.