Here at Counting Edge we take great pleasure in the emails we received. We recently received an email that revealed some disturbing details about the surveillance of blackjack players and players of other games in a live casino. The sender of the email wishes to remain anonymous, but we can tell you that they are one of the people behind the Eye in the Sky.
Your favorite live casino could be reporting your cash transactions to federal authorities. Every time that you buy-in at the blackjack table, every time you cash out, and even when you make withdrawals from an ATM could be subject to scrutiny. The reason for this? Casinos are required by the federal government to comply with something known as the BSA, or Bank Secrecy Act.
The BSA and Blackjack
The BSA or Bank Secrecy Act became United States law in 1970. It was designed to prevent money laundering and the moving of money to fund terrorist or other illegal activities. Federal law now requires all live casino personnel to receive training on how to comply with the BSA and its reporting requirements.
So, how does this impact blackjack players? For starters, most players are not even aware of the reporting requirements. They play without knowing that every transaction is being watched. The BSA mandates that once a player has $2,500 in transactions, a Multiple Transaction Log or MTL is opened on that player. Once the MTL is opened, every buy-in or cash-out is added to the log.
Let’s say that you buy-in to the blackjack game in a live casino with $500. A short while later you cash out $1,000. You go to another table and buy-in with the $1,000. You have now been identified as someone that is engaged in “suspicious” activity according to the BSA and the casino. An MTL will be opened on you and your casino activity will be placed under surveillance.
This may not sound like a big deal, but even for the small player the sum of $2,500 can add up quickly. This sum takes into account every transaction, not whether you win or lose. Let’s say that you decide to play a game of blackjack and buy-in with $100. You have an amazing run of luck and win $2,400 before cashing out $2,500. You just made the list of casino surveillance.
Cash transactions must occur during the same gaming day in order to be considered for the MTL. So, if you only have $2,499 in one gaming day, you will not be under surveillance for the BSA. Casinos can be punished harshly if they don’t comply with this regulation. They are subject to a fine of up to $500,000 and casino employees can face up to 10 years in prison. No one working at the casino is willing to do that for a blackjack player. The bottom line is that you will be monitored when your transactions exceed the limit.
The Currency Transaction Report
If you manage to accumulate $10,000 in transactions during one gaming day, a new report will be opened on you. This one is called the Currency Transaction Report and it must be filed with the government. Unlike the MTL, you will be asked to sign the CTR. If you refuse to do so, the casino is likely to ban you from gambling. They could also withhold any pending winnings that you have accumulated.
When asked to fill out a CTR the blackjack player will be asked to provide a valid ID, a Social Security Number, a physical address, and a date of birth. This information is then also forwarded to the casino’s audit department for review.
Other Suspicious Activity Blackjack Requirements
This may seem extreme, but it doesn’t stop there. The casino information that Counting Edge was provided also details the procedures for reporting so-called suspicious activity. A blackjack player can be suspected of suspicious activity by the casino at any time, without anything more than the word of a casino employee. The paperwork that we received even encourages casino employees to report patrons if the employee has a “bad gut feeling” about them!
It seems to us that this type of system encourages abuse. To give the casinos such broad-sweeping power to evaluate the intentions of patrons depends upon casino employees acting ethically in their reporting.
Once a player achieves $5,000 in transactions, a suspicious activity report is opened if the player is suspected of:
- Deriving their gambling funds from illegal activity
- Gambling in order to hide assets from the government
- Trying to evade the BSA requirements
- Having no business or lawful purpose
- Using the casino to conduct criminal activity
Having no business or lawful purpose? What exactly does that mean? Who is the casino to judge when a person has no business being in their establishment? Perhaps the most concerning part of all this is that the casino can initiate surveillance based on “unusual activity.” But the casino does not specifically document what that activity is. Is it walking in a certain manner? Is it talking to one’s self at the blackjack table? Is it not having a drink when everyone else at the table is drinking? Too much freedom is given to the casino in this designation.
One of the most disturbing things about the report that we read was that casino employees were specifically instructed not to inform patrons that a Suspicious Activity Report has been filed on them. In other words, the casino does not want you to know that they have a file on you or what is in that file.
How Blackjack Players can Avoid Surveillance at a Live Casino
One way that you can avoid falling on to the suspicious person reporting sheet is by limiting your blackjack transactions in a live casino. This may work, but the casino can always sidestep the rules and accuse you at their discretion. The best way to avoid the scrutiny of live casino surveillance is to play blackjack online.
When you play blackjack online there is no one to observe your activities. You can play from the comfort of your own home on a computer, phone, or tablet. You may even be able to achieve some anonymity when you choose a casino that accepts Bitcoin as a deposit.
Why take the risk of being reported to the federal government for playing blackjack? Play online instead. Counting Edge has reviewed and recommended several online casinos that you can join right now.