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  #1 (permalink)  
Old 07-05-2007, 10:45 AM
Rogthedodger Rogthedodger is offline
Join Date: Dec 2002
Posts: 6,871
Default Connect The Dots, and The Picture Gets Uglier - New Nevada...By Nelson Lardner

The typical big player, firing high, wide and handsome in any Nevada pit or at a high-denom slot-machine bank, has more money than sense . . . though he almost certainly knows in his heart of hearts that there'll be a price to be paid for any thrills accrued.

But it's a sure thing that this kind of guy or gal is unenthused about attracting any special government scrutiny - especially given the 99.44% mathematical probability that he or she will come out well-behind over the course of a calendar year, so long as bankroll is exposed to the vagaries of a craps tub or roulette layout on sustained, multiple occasions.

Remember Nevada Regulation 6A? Perhaps you don't . . . by that name . . . but that was the little item requiring any joint enjoying at least $10 million in annual gaming revenue to submit paperwork on anyone involved in any cash transaction of at least $10,000.

Well, that baby was repealed, as of this past weekend.

Taking its place is a federal piece of work to be henceforth referred to as Title 31, extracted from the Bank Secrecy Act. The BSA's been around awhile, but it's been a magnet for more nose-under-the-tent amendments since the advent of (surprise, surprise) The Patriot Act.

But I'll skip the remainder of the history lesson, only to point out what Title 31 means today: we're now talking about an AGGREGATE $10,000 or more of transacted business, over a 24-hour period. This includes (but is not solely-exclusive to) any cash-for-chips buyins; cash plays; check cashing; chip cashing, jackpots, tournament winnings, and/or any currency-for-currency exchanges. Whew!

This is nothing new for many other United States casino venues. New Jersey customers who do business at these levels are certainly well-familiar with it. But now Nevada action is also subject to such scrutiny.

A casino's central casino cage is now the clearing house of responsibility for this datagathering and paperwork. The manhours which will be absorbed by harried casino personnel now expected to keep tabs on all this is mindboggling.

And did I mention that the previous $10-million-a-year revenue threshold for individual properties has been lowered ninety percent, to a mere $1,000,000?

You can hear the gnashing of teeth from here.

This is outrageously-presumptuous at the federal level. Required paperwork will increase exponentially (one reasonable estimate? 400%). And casinos - and their floor employees - wind up responsible for doing the federale's bidding . . . and will be subject to fines and associated punishments if they don't dot i's and cross t's. Casino people figure to feel like Scarlet O'Hara's mule before too long. Compared to constant whipping and broad abuse, collapse and the Big Sleep will seem a preferable option.

I do not advocate tax evasion. If you win prizes in contests, or you make a significant lottery or racetrack score, you would be well-advised to make note of it on your taxes. If you're still a loser in a particular year on your betting (you do keep records, do you not?), you itemize, and avoid the bite.

Having said that, feel safe in making an observation which while not urging evasion, remains strongly rooted in logic, and a developed understanding of human nature: the implementation of Title 31 is going to result in a good deal more casino-hopping than you're seeing now, in order to avoid reaching the new thresholds in individual establishments. If someone's approaching the magic number at Paris, they may well take a stroll to Planet Hollywood or the Venetian, to avoid intrusive scrutiny by floor people themselves unwilling to give the appearance of lax diligence.

With that on the record . . . who's kidding who? Since heavy, habitual pit players are most-unlikely winners, over the course of a year's gambling, what's the big deal? Carping about money-laundering in this situation is a canard . . . running money through a heavy casino-craps session, or a few "21" shoes, can get damned expensive. A simple DOJ/Treasury agenda of intrusion, in a Patriot Act-facilitaed attempt to spotlight folks with the kind of disposable income that allows sustained high-roller forays? You'd like not to think so, but . . .

Let's get something else out there, one more time. The United States remains the lone civilized Western nation which taxes gambling winnings banked by non-professionals. IRS treatment of gambling profits is punitive, on so many levels, and when you start talking about windfall lottery winnings, the total percentage of lottery prize money which gets appropriated in fatty, chunky, meaty slices is grotesque, especially given the calculated takeout cleaved off the top with daily Pick-Threes, Pick-Fours, and other self-inflicted taxes on the stupid. Though flawed on multiple levels, even a plan such as Barney Frank's might find far smoother-sailing from the public (once tweaked), if the IRS deigned to allow any non-professional gambler to retain any gambling winnings, tax-free. Now THAT is a talking point.

There are other potential, non-regressive government grabs far more reasonable than sustaining this caliber of discriminative revenue glom. Increased tobacco and liquor taxes are fair game. There are others. Surprise us. How refreshing it would be if congress actually did the best thing for the most people (and that means any thought of increasing gasoline taxes is flat-out off the table - hear that, Dems?), quit sucking up to pet campaign contributors, and act like statesmen. It's not too late - and you can't imagine how well-received it would be.

Nelson Lardner
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Old 07-05-2007, 03:47 PM
stevo stevo is offline
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Join Date: Jul 2002
Posts: 64,876

A casino's central casino cage is now the clearing house of responsibility for this datagathering and paperwork. The manhours which will be absorbed by harried casino personnel now expected to keep tabs on all this is mindboggling.

I want to see this in action. Its gotta be hard. Plus the lowering of the threshold a killer for small places.
The purpose of life is not to be happy. It is to be useful, to be honorable, to be compassionate, to have it make some difference that you have lived and lived well.

Ralph Waldo Emerson
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Old 07-05-2007, 04:08 PM
Highwayman Highwayman is offline
Join Date: Sep 2006
Posts: 1,330


Note that the Financial Crimes Enforcement Network (FinCEN) made a ruling on 6/21/07 that exempts slot jackpots recorded on a W2G from being logged on a Slot MTL and, specifically, a CTRC-N.

Meaning, the only cash transactions that will have to be logged on the Slot MTL/CTRC-N and new “watch dog” program is slot ticket redemption, cash marker issuant, chip redemption and check cashing transactions.

The threshold for logging these cash transactions is $3,000. Title 31 program will still “data mine” cash bills inserted in the slot machines (assuming patron has inserted their club-card in the machine). The “watch dog” feature will show when a patron has inserted cash into a slot machine automatically starting at $3,000.

Slot personnel will not have to log W2G slot jackpots on the Title 31…yet all slot personnel will have to remain vigilance in the prevention of potential money laundering activates per the SARQ (Suspicious Activities Report).

“Governments’ should NOT encourage nor profit from any social vices while passively acknowledging their existence amongst all societies and cultures.” -HWM
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Old 07-05-2007, 07:48 PM
Mr Negative Mr Negative is offline
Join Date: Sep 2002
Posts: 4,398

Betting with chips in sportsbook does not count towards your 10K under Title 31?
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Old 07-07-2007, 12:57 AM
Juice Juice is offline
Join Date: Dec 2005
Posts: 3,812

There is no real shot at enforcing it IMHO. Unless you count doing a bunch of paperwork as enforcement. That or firing people for not doing enough paperwork, so as to appear they are trying to enforce the law.
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