Considering the U.S. Federal Government has taken
upon itself to begin tracking smaller cash transactions (albeit quite large in
the grand scheme of things) in order to prevent and curb money laundering, the
Nevada Gaming Commission has had no other choice but to terminate a twenty-one
year gaming law known as Regulation 6A, which required casinos to track cash
transactions of $3,000 or more as well as report any transactions over $10,000
to the Internal Revenue Service. Since the federal government is now requiring
casinos that bring in more than $1 million in yearly gross gambling revenue to
abide by the same income reporting requirements that casinos making over $10
million annually are subjected to, the reporting threshold imposed by Regulation
6A and the new federal guidelines are one and the same.
Understandably so, there have been no complaints by
the Gaming Control Board. If they opted to conform to the new federal standards,
the number of casinos required to report under their dominion would have been
more than doubled from 115 to a whopping 260. As expressed by Gaming
Commissioner Art Marshall, rather than tie up Gaming Control Board agents even
more than they already are having to keep up with the duties that Regulation 6A
required, these very same agents can now be used to complete other tasks in a
more timely manner, such as performing taxation audits.
The impetus for the changes in federal policy was
ushered in by the Patriot Act, which prior to being passed, Nevada was the only
U.S. State tracking large cash transactions for purposes of safeguarding against
and detecting money laundering. With the passing of the Patriot Act, more
authority was given to Title 31 of the Bank Secrecy Act, and casinos were to be
classified as financial institutions. Now it will be the job of the Financial
Crimes Enforcement Network to wade through the millions of dollars of cash
transactions made by casino gamblers in the State of Nevada.
Although the new regulations could make things more
difficult for smaller casino operators, no objections of the proposal to
terminate Regulation 6A surfaced. Essentially, casino operators understand that
the federal guidelines supersede Regulation 6A, and that if any dissension was
to be expressed, it would need to be directed at the Patriot Act. Gaming Control
Board Chairman, Dennis Neilander, did say that the Las Vegas Gaming Institute,
the IRS and University of Nevada were all contacted about developing educational
programs to help the audit departments of casinos adopt and implement the new
guidelines. The second public hearing held by the Nevada Gaming Commission gave
the final ruling on the matter.