Casino tokens (also known as casino or gaming chips, checks, or cheques) are small discs used in lieu of currency in casinos.Colored metal, injection-molded plastic or compression molded clay tokens of various denominations are used primarily in table games, as opposed to metal token coins, used primarily in slot machines.Casino tokens are also widely used as play money in casual or tournament.
Once casino software providers like Microgaming, Real time Gaming and Playtech began to move toward the markets outside the USA it turned out to be important that they accept players to wager in various currencies. The major casino markets outside the USA are Canada, Europe and Asia. Online casinos powered by these software providers accept currencies such as Canadian Dollars (CAD), Euros (EUR), Pounds and US Dollars. For example a Euro online casino mainly accepts deposits in Euros but also accepts other currencies because there are many Europeans players that are based outside of Europe.
Players can choose the desired currency that they want to use when registering at the online casino. Thereon, all financial transactions will be made in the currency chosen by the player. Players are able to wager in their native currency and do not need to convert them to US dollars, which is the main currency used in the online casino gambling industry. Because of this they do not lose out on the exchange rates and bank costs.
For this purpose, players need to consider what type of currency they want to wager before choosing the option available at the casino as it is a very tiresome process. If they need to make any changes later on they cannot do it by themselves and will have to seek help from the casinos’ customer support.
It is still complicated after that as players will be asked to first clear their dues on bonuses in the existing currency and only after that will they be able to make any withdrawals from their casino accounts. After this the customer reps will change the currency settings and allow the player to make deposits in the new currency.
One of the most common methods of getting players is to give them online casino bonuses to use for playing games. For example, Slots Oasis Casino gives all new players a $4000 welcome bonus. What does this mean for a UK player for example? Well this casino does all transactions using USA $ Dollars, so they would work out the equivalent in UK Pounds Sterling or in Euro’s for European players.
It is not complicated at all and the casinos do all the work for you so you can just concentrate on the playing side. All online casinos accept all currencies, even if some do not accept USA players, they will still accept USA dollars because USA dollars are used in other countries and it is a global currency.
You are able to switch currencies in your casino account. You will need to contact the casinos customer support to get all the details on doing it and if there are any terms and conditions associated with it. So overall, all online casinos advertise their bonuses in US dollars, but they accept all currencies, no matter where in the world you are.
Dear [ ]:
I am writing in response to your letter of November 18, 2004 to the Financial Crimes Enforcement Network requesting, on behalf of the [Regulatory Office], an administrative ruling that interprets the Bank Secrecy Act requirement to report casino currency transactions in excess of $10,000 in a gaming day.1
Specifically, you have requested a determination as to whether and when a cash wager on table game play represents a “bet of currency” and thus a transaction in currency involving “cash in” pursuant to 31 C.F.R. § 103.22. Based on the representations made in your letter, and as explained more fully below, the cash wagers you describe would be bets of currency2 and therefore subject to currency transaction reporting and associated aggregation requirements.3
BACKGROUND:
You represent in your letter that the Regulatory Office regulates the tribal gaming facilities of the [Casino]. According to your letter, the Casino accepts cash wagers/bets on table game play4 but does not consistently treat cash wagers as transactions in currency involving “cash in.” More specifically, the Casino does not consider the mere placing of a cash wager/bet by a customer to be a cash-in transaction for purposes of currency transaction reporting. Rather, the Casino treats losing cash wagers as cash-in transactions, but winning cash wagers are not considered transactions in currency involving cash in.
You have asked the following questions:
• What is the definition of the term “bet of currency”?
• At what point does a cash wager placed on the gaming table become a bet of currency?
• When is the cash wager considered a “transaction in currency” and therefore determined to be “cash in”?
• Is the Casino required to recognize the cash wager on a winning bet as “cash in”?
ANALYSIS:
Per 31 C.F.R. § 103.22, casinos are required to file Currency Transaction Reports for “cash in” transactions of more than $10,000, to include “bets of currency.”5 The term “bet of currency” is not defined in the regulation. It is our view that, for purposes of Bank Secrecy Act currency transaction reporting requirements, a cash wager at a table game would become a bet of currency once the customer can no longer retrieve the bet (e.g., once the dealer has dealt the cards). At that point, the customer has put his or her cash at risk by wagering it on the outcome of: (a) games that involve a mixture of chance and skill; or (b) an uncertain event, over which the bettor exercises no control or which is determined by chance. Once the cash wager is placed, the customer is gambling against the Casino, and would be deemed to have engaged in a physical transfer of the currency to the Casino to participate in the game.6 Consequently, the cash wager is a cash-in transaction for purposes of the currency transaction reporting requirements regardless of whether the customer subsequently wins or loses the wager.7
Additionally, the provision that governs whether the Casino must aggregate transactions in currency conditions the requirement to aggregate upon knowledge that this obligation has been triggered:8
[M]ultiple currency transactions shall be treated as a single transaction if the casino has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any gaming day.
Knowledge by a Casino means knowledge by an officer, director, employee, partner, or sole proprietor of the Casino. The officer, director, employee, partner, or sole proprietor could acquire knowledge of the information through any means, including observation and as specifically stated in the regulations from “examining” the books, records, logs, computer files, etc. that contain information that the currency transactions have occurred.9 For example, such examination would occur by reviewing a casino’s player rating system records.10
In arriving at the determinations in this administrative ruling, we have relied upon the accuracy and completeness of the representations in your letter. Nothing precludes us from seeking further action should any of these representations prove inaccurate or incomplete. We reserve the right to publish this administrative ruling as guidance, with information identifying you, the Regulatory Office, and the Casino redacted.11 You will have 14 days after the date of this administrative ruling to identify any other information you believe should be redacted and the legal basis for the redaction.
If you have additional questions, please contact Leonard C. Senia, Senior Regulatory Compliance Specialist, at (202) 354-6412.
Sincerely,
/signed/
William D. Langford, Jr.
Associate Director
Regulatory Policy and Programs Division
1See 31 C.F.R. § 103.22(b).
2See 31 C.F.R § 103.22(b)(2)(i)(E).
3See 31 C.F.R. § 103.22(b)(2) and (c)(3).
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4For purposes of this ruling, we have assumed that the transactions at issue are “money plays”; that is, transactions in which the customer places a currency bet on the table prior to the beginning of play, where the dealer does not exchange the currency for chips and the currency is not put into the drop box. Thereafter, the game is played, and if the customer wins the dealer pays the customer in chips; whereas if the customer loses, the dealer puts the currency in the drop box.
5See 31 C.F.R. § 103.22(b)(2)(i).
6See 31 C.F.R. § 103.11(ii)(2); 31 C.F.R. § 103.22(b)(2).
731 C.F.R. § 103.22(b)(2)(i)(E) makes no reference whatsoever to winning or losing the “bet of currency.”
8See 31 C.F.R. § 103.22(c)(3).
Casino Windsor Money Exchange
9See 31 C.F.R. § 103.22(c)(3).
Crown Casino Money Exchange
10See 31 C.F.R. § 103.36(b)(8) - records prepared or used to monitor a customer's gaming activity.
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11See 31 C.F.R. § 103.81(a)(5).