Casinos are a magnet for money laundering activity due to their high volume of cash transactions and the ease with which funds can be moved in and out. At Sigal Law Group, we've seen how federal authorities aggressively pursue both individuals and businesses for violations of anti-money laundering laws, especially Title 31 of the Bank Secrecy Act. Understanding common methods used to disguise illicit funds and the severe penalties for non-compliance with federal regulations like Title 31 is critical for anyone involved in gaming operations.

How Money Laundering Happens in Casinos

One common tactic is “chip walking.” Here, someone buys chips with large amounts of cash, makes minimal bets, and then cashes out, claiming the funds as gambling winnings. This makes dirty money look legitimate. Another scheme involves collusion, where groups of players purposely lose chips to one another, creating a paper trail of “winnings” that can be withdrawn as clean money. More recently, some criminals have used cryptocurrency to deposit funds, gamble just enough to avoid suspicion, and then withdraw their money as cash.

Casinos are required by law to report any transaction over $10,000 and to file Suspicious Activity Reports (SARs) when they suspect money laundering. When these requirements are ignored or handled improperly, the consequences can be severe.

Penalties for Title 31 Non-Compliance

Failure to comply with Title 31 can result in both civil and criminal penalties. Civil fines can reach up to $50,000 for negligent violations, and willful violations can lead to daily fines of $25,000 to $100,000-plus forfeiture of the transaction amount. Criminal penalties are even steeper: individuals can face up to 10 years in prison and fines up to $500,000. Casinos themselves have paid multi-million-dollar settlements for systemic failures, and executives have faced prosecution for turning a blind eye to illicit transactions.

If you or your business is under investigation for money laundering or Title 31 violations, early intervention by experienced criminal defense counsel is essential. At Sigal Law Group, we know how to challenge the government's case and protect your rights every step of the way. Contact our offices today for a free consultation.