Pursuant to 31 CFR 1021.410(a), with respect to each deposit of funds, account opened, or line of credit extended, a casino is required to secure and maintain a record of the name, permanent address (address), and Social Security number (SSN) of the person involved at the time the funds are deposited, the account is opened, or credit is extended. Where the deposit, account, or line of credit is in the name of two or more persons, the casino must secure the name, address, and SSN of each person having a financial interest in the deposit, account, or line of credit. The casino is required to verify the name and address of such person(s) at the time the deposit is made, the account is opened, or credit is extended, by the examination of a document as described in 31 CFR 1010.312. The specific identifying information relied upon must be recorded by the casino in the manner described in 31 CFR 1010.312. If a casino is unable to secure the required SSNs, the casino will not be deemed to be in violation of 31 CFR 1021.410 if the casino has made reasonable efforts to secure the SSNs, and it maintains a list of the names and addresses of those persons from whom the casino was unable to obtain the SSNs. Pursuant to 31 CFR 1021.410(b), casinos must retain either the original or a copy of each of the following: (1) a record of each time the casino receives funds for credit to, or deposit into, any personâs account, including the name, address, and SSN of the person from whom the casino receives the funds, the date of receipt of the funds and the amount received; (2) a record of each bookkeeping entry made to a customerâs deposit or credit account with the casino; (3) each statement, ledger card, or other record of each deposit or credit account with the casino, showing each transaction in or with respect to a customerâs account with the casino; (4) a record of each extension of credit in excess of $2,500, the terms and conditions of each such extension of credit, and repayments, and the customerâs name, address, SSN, and the date and amount of the transaction (including repayments); (5) a record of each advice, request or instruction received or given by the casino with respect to a transaction involving a person, account, or place outside the United States; (6) records prepared or received by the casino in the ordinary course of business that would be needed to reconstruct a personâs deposit or credit account with the casino or that would be needed to trace a check deposited with the casino through the casinoâs records to the bank of deposit; (7) all records, documents, or manuals required to be maintained by a casino under state and local laws or regulations, and regulations of any governing Indian tribe or tribal government; (8) all records which are prepared or used by a casino to monitor a customerâs gaming activity; (9) a separate record containing a list of each transaction between the casino and its customers involving the following types of instruments having a face value of $3,000 or more: (i) personal checks; (ii) business checks; (iii) official bank checks; (iv) cashierâs checks; (v) third-party checks; (vi) promissory notes; (vii) travelerâs checks; and (viii) money orders; (10) a copy of the compliance program described in 31 CFR 1021.210(b); (11) for card clubs only, records of all currency transactions by customers, including, without limitation, records in the form of currency transaction logs and multiple currency transaction logs, and records of all activity at cages or similar facilities, including cage control logs. Pursuant to 31 CFR 1021.410(c), casinos that input, store, or retain, in whole or in part, for any period of time, any record required to be maintained by by 31 CFR 1010.410 or 31 CFR 1021.410 on computer disk, tape, or other machine-readable media must retain those records in the same format.
Since the 2022 renewal, FinCEN has revised its assessment of the time necessary to conduct the tasks associated with this renewal. FinCEN has reduced its estimate of total annual burden by 9,774 hours, specifically, from the 128,637 hours previously estimated in 2022 to 118,863 hours upon this renewal in 2025. This decrease reflects FinCENâs incorporation of additional data and information that was unavailable at the prior renewal.
At the time of the 2022 renewal, FinCEN lacked data on the number of certain types of covered casinos (specifically, card clubs), casinosâ annual volumes of covered transactions, and their rate of technological adoption. As a result, in the 2022 renewal, FinCEN considered it the most prudent approach to apply a higher uniform estimate of the requisite recordkeeping burden hours. FinCEN has since updated its estimation methodology (including the hourly burden for select recordkeeping tasks, as discussed in the 60-day notice) to better align estimates of incremental burden with current market practices.
The decrease in the estimated incremental burden reflects a decrease in the estimated burden stemming from maintaining customer information (31 CFR 1021.410(a)) and maintaining records of other covered transactions (31 CFR 1021.410(b)(1)-(9) and (c)(1)-(2)). FinCEN has applied data from SARs to more accurately estimate the annual volume of these transactions. FinCEN has also decreased its estimate of the documentation burden for cash transactions at card rooms (31 CFR 1021.410(b)(11)). FinCEN notes that most card rooms do a significant portion of their business in cash, as evidenced by analysis of their CTR filings, and consequently FinCEN revised its estimates of the number of transactions that engender recordkeeping activity upwards. However, because recordkeeping is now predominantly conducted using digital technology in the ordinary course of business, FinCEN is reducing its incremental burden estimate per record to two minutes per transaction on average. Finally, FinCEN is aligning the burden estimates for 31 CFR 1021.410(c)(1) and (2) with its analogous updates in OMB control number 1506-0051, which removed an incremental burden estimate for maintaining electronic or digitally generated records, and the materials necessary to navigate those records, in the same format in which they were originally created.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
PC_202507-1506-002_080625_054726_1.pdf
1506-0054 Casino Recordkeeping Supporting Stmt 7_8_2025 FINAL.docx
31 CFR 1021.410(c)