Pending Changes to FinCEN CTR and SAR Reporting

As we reach the end of 2011 and head into 2012, FinCEN has been working on modernizing and standardizing the process for submitting CTR and SAR forms for all financial institutions, including casino properties. This process changes not only the content of the forms, but it also affects how the forms are to be filed in the near term, as well as the long term.

Deadline - September 30, 2011 - Though this deadline has come and gone, properties that file CTR-Cs and SAR-Cs via paper hard copy should be reminded that the most current versions of the FinCEN Form 103 (CTR-C) and FinCEN Form 102 (SAR-C) are dated "March 2011"; older versions of these forms are considered unacceptable by FinCEN if they were filed after September 30, 2011. You can check the version of your forms by looking in the upper left corner for the FinCEN version date "March 2011". If you have not yet changed your CTR-C or SAR-C template to the current version, click here to download the March 2011 versions for your property's use going forward.

Note: If your property is currently filing CTR-Cs or SAR-Cs electronically through Resort Advantage eSubmission, then you will not have to do anything additional

Deadline - December 1, 2011 - The next significant change goes into effect on Thursday, December 1, 2011. This change is related to how casinos will file corrections or amendments to CTR-C and SAR-C forms. When correcting or amending a previously filed paper form (e.g. hard-copy), filers must check the appropriate "amendment" or "correction" box at the top of the form and complete the balance of the form in its entirety, essentially creating a new, fully revised filing. Further, casinos should no longer attach copies of previously filed reports to a corrected or amended form when mailing them in.


Note: If your property is currently filing CTR-Cs or SAR-Cs electronically through Resort Advantage eSubmission, then you will not have to do anything additional

However, if your property is still filing CTR-Cs via hard copy printing and mailing, then you should closely review your process for filing hard-copy corrections or amendments.  

Deadline - June 30, 2012 - FinCEN's recent proposal that all reports required under the Bank Secrecy Act (BSA) are to be filed electronically as of June 30, 2012, has the casino industry quickly moving to implement solutions to address this requirement. Standardization of CTR and SAR reporting across all financial institutions will result in more efficient and timely analysis of filing data by FinCEN. Further, industry-specific versions of the reports (e.g. CTR-X and SAR-X) will be replaced by universal versions: FinCEN Form 112 (CTR) and FinCEN Form 111 (SAR).

Under this proposal, casinos will be required to file 100% of its CTRs and SARs electronically with BSA after June 30th. The BSA website will continue to support a manual entry filing-by-filing protocol, but the clear desire is for properties with batches of CTRs and SARs to file them electronically through a direct secure connection to FinCEN / BSA, such as that provided by Resort Advantage's eSubmission capabilities. This approach yields the most efficient filing process, using a multi-step batch create/approve/submit protocol, as well as the most complete filing audit trail.

Note: If your property is currently filing CTR-Cs or SAR-Cs electronically through Resort Advantage eSubmission, then you will not have to do anything additional

More details on this transition will be provided in future Resort Advantage eNewsletters and upcoming Compliance Alert! Webinars.