Guideline 10A: Submitting Casino Disbursement Reports to FINTRAC Electronically

Appendix 4: Examples of Reasons and Methods for Casino Disbursement Reports

The following examples are to help explain when and why a casino disbursement report (CDR) is required for common casino transactions.

Examples 1 to 3 are commonly occurring transactions at a casino for which a CDR will be required. Examples 4 and 5 are likely to occur less frequently, but are provided to highlight other reportable disbursement transactions. In each case for examples 1 to 5, the disbursement is requested by one casino patron during a single transaction (for example, one visit to a cashier's station).

Examples 6 to 8 are about situations where a casino disbursement report will not be required. Example 9 is about multiple transactions involving the 24-hour rule.

For all examples, funds are in Canadian dollars unless otherwise specified. In addition, where a CDR is required, only the information required in fields F1-1 to F1-4 of Part F1 (Reason for disbursement) and fields F2-1 to F2-4 of Part F2 (Method of disbursement) is explained. Although all other applicable parts and fields of the CDR would also be required, these examples illustrate only basic reason and method information.

Example 1

A patron redeems $11,000 in slot tickets for $11,000 in cash.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

  • Reason: Redemption of slot tickets, 11,000 CAD
  • Method: Paid out in cash, 11,000 CAD

Example 2

A patron redeems $25,000 in casino chips for a $25,000 casino cheque.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

  • Reason: Redemption of chips or tokens, 25,000 CAD
  • Method: Issued a cheque, 25,000 CAD

Example 3

A patron redeems slot tickets for $ 12,000 and casino chips for $5,000. In exchange, he receives a cheque for $7,000 and $10,000 in cash.

A CDR is required, with one transaction including the following information about the two reasons and the two methods of disbursement.

  • Reason 1: Redemption of slot tickets, 12,000 CAD
  • Reason 2: Redemption of chips or tokens, 5,000 CAD
  • Method 1: Issued a cheque, 7,000 CAD
  • Method 2: Paid out in cash, 10,000 CAD

Example 4

A patron withdraws $24,000 from her front money account in exchange for a casino cheque for $24,000.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

  • Reason: Front cash withdrawal, 24,000 CAD
  • Method: Issued a cheque, 24,000 CAD

Example 5

A patron withdraws $44,000 from his front money account and requests the casino to wire the funds to his bank in the United States.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

  • Reason : Front cash withdrawal, 44,000 CAD
  • Method : Sent international funds transfer, 44,000 CAD

In this example, a casino disbursement report is required even though the funds were sent by wire transfer. This applies to any disbursement involving a wire transfer, whether domestic or international. As explained in subsection 2.4 of this guideline, if a casino disbursement involves an international wire transfer, you may have to make an electronic funds transfer report to FINTRAC about the same transaction in addition to the CDR.

Example 6

A patron cashes a $10,000 personal cheque (that is made payable to the patron) in exchange for $10,000 in chips.

A CDR is not required. Although the cashing of a $10,000 cheque could be a reportable disbursement, it is not in this example because of how it was paid out. Pay outs in casino chips are not considered to be a disbursement in this context.

Example 7

A patron cashes a casino cheque for $11,000. In exchange, she receives $6,000 in cash and $5,000 in chips.

A CDR is not required. Although the reason for disbursement (cashing of a cheque) is over $10,000, the method of disbursement is less than $10,000 because the amount paid out in casino chips is excluded. A CDR is only required when both the reason and the method of a disbursement (as explained in subsection 2.2 of this guideline) equal $10,000 or more.

If the payout in this example had been $10,000 in cash and $1,000 in chips, a CDR would have been required.

Example 8

A patron withdraws $5,000 from his casino front money account and requests a cash advance on his bank-issued credit card for $5,000. In exchange, he receives a cheque for $10,000.

A CDR is not required. Although the amount paid out is $10,000, the reason for disbursement is less than $10,000 because an advance on a bank-issued credit card is not considered a disbursement. A CDR is only required when both the reason and the method of a disbursement (as explained in subsection 2.2 of this guideline) equal $10,000 or more.

Example 9

This example has two scenarios.

Scenario 1

The following transactions occur at the following times, on the same day:

  • At 2:00 p.m., a patron exchanges $5,000 cash (United States dollars) for $5,500 cash (Canadian dollars).
  • At 4:00 p.m., the same patron redeems a $7,000 slot ticket for $7,000 cash.
  • At 8:00 p.m., the same patron exchanges $5,000 cash (United States dollars) and redeems $3,000 in casino chips for $8,500 cash (Canadian dollars).

A CDR is required under the 24-hour rule for the 4:00 p.m. transaction and the 8:00 p.m. transaction, as follows.

  • Transaction 1 (from 4:00 p.m.):
    • Reason: Redemption of slot tickets, 7,000 CAD
    • Method: Paid out in cash, 7,000 CAD
  • Transaction 2 (from 8:00 p.m.):
    • Reason: Redemption of chips or tokens, 3,000 CAD
    • Method: Paid out in cash, 3,000 CAD

Scenario 2

The same transactions as scenario 1, with the following change to how the payout is made at 8:00 p.m.:

  • At 8:00 p.m., the same patron exchanges $5,000 cash (United States dollars) and redeems $3,000 in casino chips for a cheque in the amount of $8,500 (Canadian dollars).

A CDR is required under the 24-hour rule for the 4:00 p.m. transaction and the 8:00 p.m. transaction as follows.

  • Transaction 1:
    • Reason: Redemption of slot tickets, 7,000 CAD
    • Method: Paid out in cash, 7,000 CAD
  • Transaction 2:
    • Reason: Redemption of chips or tokens, 3,000 CAD
    • Method: Issued a cheque 8,500 CAD

In this scenario, the method reported for transaction 2 is the full amount of the casino cheque, even if it includes an amount that is a not reportable as a disbursement. The cash being exchanged is not included in the CDR as a reason for disbursement. However, the portion of that transaction that is the redemption of casino chips is included because, when added to the reason of disbursement in transaction 1, the threshold of $10,000 or more has been met.

In both scenarios of this example, in addition to a CDR, a large cash transaction report (LCTR) would also be required. The LCTR 24-hour rule applies to the 2:00 p.m. and 8:00 p.m. foreign currency exchange transactions. For more information about when LCTRs are required, see Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC.