When licensed casinos are involved in an international funds transfer (IFTI), they must submit an international funds transfer instruction (IFTI) report to AUSTRAC. An IFTI is an electronic instruction to transfer money to Australia from a foreign country or to a foreign country from Australia.
There are two types of IFTIs – IFTI-DRAs and IFTI-Es. Casinos make IFTI-DRAs because the transfer instructions are made under a designated remittance arrangement.
Casinos must submit IFTI reports within 10 business days after the day the transfer instructions were sent or received.
Common international funds transfers made by casinos
The six examples illustrate common situations in which casinos are involved in international funds transfers that they must report to AUSTRAC. These are not the only situations in which casinos might have to report IFTIs.
In some of the examples, a bank must make an IFTI report about a transaction that a casino is involved in. Note that even when this is the case, the casino must still submit its own IFTI-DRA report about the funds transfer. Casinos’ IFTI-DRA reports are important to AUSTRAC because casinos are required to report information about who is receiving the transferred funds – information the bank might not know or might not include in the bank’s report.
Scenario 1: Incoming IFTI-DRA
Mr A lives overseas and negotiates a ‘casino player’ agreement with an Australian casino. The agreement is finalised at the casino’s international office in a foreign country. It contains the date of the visit and the amount Mr A will deposit in the casino’s bank account before the visit.
As part of the agreement, Mr A instructs his local bank in his own country to transfer A$150,000 to the casino’s bank account, which is held with a bank in Australia. The casino credits the money to Mr A’s gaming account once the funds are received into its bank account.
Reporting obligation
The Australian casino received the IFTI-DRA transmitted into Australia and must report it as an incoming IFTI-DRA to AUSTRAC. See more about the details required in IFTI reports.
Scenario 2: Outgoing IFTI-DRA
Ms B instructs an Australian casino to transfer A$150,000 from her gaming account to the personal bank account she holds with an overseas bank. The casino instructs its Australian bank to transfer the funds to Ms B’s overseas bank account.
Reporting obligation
The Australian casino sent the IFTI-DRA out of Australia and so must report it as an outgoing IFTI-DRA to AUSTRAC. The same obligation would apply if Ms B had asked the casino to transfer the funds from her gaming account to any other overseas bank account (such as another casino’s account or another person’s account). See more about the details required in IFTI reports.
Scenario 3: Outgoing IFTI-DRA – inter-company transfer
An Australian casino has a related casino in another country (meaning the two casinos are owned or operated by the same parent company). Ms C instructs the Australian casino to transfer A$150,000 from the gaming account she holds in Australia to the gaming account she holds at the related foreign casino.
Because the two casinos are owned or operated by the same parent company, they use an inter-company journal entry to make the money available to Ms C at the overseas casino, based on the funds in her gaming account with the Australian casino. There is no physical transfer of funds and a bank isn’t involved in the transfer.
Reporting obligation
The Australian casino sent the IFTI-DRA out of Australia and must report it as an outgoing IFTI-DRA to AUSTRAC. In this case, Ms C is both the sender and receiver of the funds. See more about the details required in IFTI reports.
Scenario 4: Incoming IFTI-DRA – inter-company transfer
A foreign casino has a related casino in Australia (meaning the two casinos are owned or operated by the same parent company). Ms D instructs the overseas casino to transfer the equivalent of A$150,000 from the gaming account she holds with them to the gaming account she holds at the related Australian casino.
Because the two casinos are owned or operated by the same parent company, they use an inter-company journal entry to make the money available to Ms D at the foreign casino, based on the funds in her gaming account with the Australian casino. There is no physical transfer of funds and a bank isn’t involved in the transfer.
Reporting obligation
The Australian casino received the IFTI-DRA sent into Australia and must report it as an incoming IFTI-DRA to AUSTRAC. See more about the details required in IFTI reports.
Scenario 5: Outgoing IFTI-DRA – international transfer of funds via cheque
Mr E lives outside Australia, but has a casino gaming account with an Australian casino. He gives a cheque worth A$150,000 to staff at the casino’s international office so that it will be available in his gaming account with the Australian casino. The staff deposit the cheque into an account the casino holds with a foreign bank. The proceeds of the cheque remain in that account. The international staff notify the casino about the transaction, and the casino prepares the funds for Mr E’s arrival in Australia based on the funds held in the casino’s overseas bank account.
Mr E arrives at the Australian casino and A$150,000 is made available in his gaming account.
Reporting obligation
The Australian casino received the IFTI-DRA sent into Australia and must report it as an incoming IFTI-DRA to AUSTRAC. See more about the details required in IFTI reports.
Scenario 6: Outgoing IFTI-DRA – international transfer via a subsidiary company’s bank account
An Australian casino owns and controls a subsidiary company in Australia which has an account with an Australian bank. The state casino regulator has approved and authorised the bank account because the subsidiary company is a 100% owned and controlled entity of the casino.
While at the casino, Mr F instructs the casino to transfer A$150,000 from the subsidiary company’s bank account to his personal overseas bank account.
Reporting obligation
The Australian casino instructs the local bank to transfer the money to Mr F’s overseas account from the subsidiary company’s bank account, so it is the sender of the IFTI-DRA out of Australia and must report it as an outgoing IFTI-DRA to AUSTRAC. See more about the details required in IFTI reports.
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