In reaching the determination, FinCEN has relied on the representations in your letters, and on the scope of your request for an administrative ruling. § 103.22(c)(3) requires the Casinos to aggregate transactions in currency at slot machines. You raise questions relating to aggregation and the insertion of currency into slot machines through bill validators.įinCEN has determined that nothing in 31 C.F.R. § 103.22(c)(3), the provision governing whether a casino must aggregate transactions in currency. In your letters, you request, on behalf of and (each a “Casino”), an administrative ruling that interprets 31 C.F.R. This letter responds to your letters, dated Jand December 7, 2004, to the Financial Crimes Enforcement Network (“FinCEN”).
