CASINO-SE-001Critical Risk
sanctions evasion
Red Flag
Foreign national uses casino markers or front money to access U.S. dollar liquidity, then requests settlement through a third-party processor in a non-sanctioned country to avoid direct U.S. banking exposure.
Industry
Casinos & Card Clubs
Transaction Type
wire
Customer Type
foreign national
Category
Regulatory Source
Document:FIN-2022-RUSSIABIS Export Evasion
Type:FinCEN Advisory
CFR Citation:31 CFR §501
SAR Category:Sanctions evasion
FinCEN Key Term:Marker Settlement Evasion
Last Verified:2026-04-15
This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.