Casinos generate an enormous number of transactions every day and consequently need a Title 31 system that is able to efficiently and effectively collect transaction data, track patrons and report to FINCEN.

The Financial Crimes Enforcement Network (FinCEN) announced on 09/14/2011 that FinCEN reports required under the Bank Secrecy Act (BSA) be filed electronically as from 06/30/2012. All CTR (Currency Transaction Report) and SAR (Suspicious Activity Report) forms must be completed electronically; no paper version will be available.

These title 31 compliance changes are requirements, and casinos must be in compliance or risk fines which could number in the hundreds of thousands of dollars. Further, without software automation these changes will require extensive data entry on the BSA site. FinCEN estimates that each new CTR will take approximately 40 minutes to complete while each new SAR will take approximately two hours. Consequently, casinos will have to either staff-up considerably, adding FTE expenses, or invest in software that will auto-populate and auto-submit SAR and CTR forms.

COMPLEYE, CHEETEYE’s title 31 compliance software tool helps casinos comply with FinCEN’s CTR and SAR electronic filing requirements. It provides a link into most player rating systems which allows users to auto-populate parts of the CTR and SAR forms. Our software auto-submits completed forms to FinCEN and can be used simultaneously by multiple operational and management staff, making it a very cost-effective title 31 compliance solution.


  • Interface with most casino management systems (CMS) to collect cash-in and cash-out transactions for the Multiple Transaction Log (MTL).
  • Electronically track cash-in and cash-out transactions, single or aggregate for a game day. Transactions will be documented and itemized on one MTL per individual per game day. Employees also have the ability to log manual MTL transactions.
  • Transaction audit trails.
  • Store IRS forms electronically.
  • Verify a guest’s SSN with the IRS and Specially Designated Nationals and Blocked Persons List (SDN).
  • Notify employees when a guest is approaching a CTR, to obtain the required information.
  • Prepare CTR(s) automatically with edit capabilities.
  • Populate SAR(s) required information automatically with edit capabilities.
  • Submit CTR(s) and SAR(s) electronically to FINCEN and allow users to make corrections to CTR(s) or SAR(s) after submittal to FINCEN, in the event of an error.
  • Ability to collaborate with Surveillance and other departments on SAR forms.