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#2307929 - 04/09/25 06:20 PM Social Clubs
Loriann44 Offline
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Joined: Dec 2016
Posts: 9
Are social clubs like The American Legion, Fraternal Order of the Eagles, Moose Lodge, etc able to be made exempt from CTRs? They do have pull tabs, slot machines, and drawings but are mainly supposed to be fund raisers for the community.
Last edited by Loriann44; 04/09/25 06:23 PM.
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#2307937 - 04/09/25 08:19 PM Re: Social Clubs Loriann44
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,707
It would depend on the activities of the specific organization:

8) Ineligible businesses. A business engaged primarily in one or more of the following activities may not be treated as a non-listed business for purposes of this section: Serving as financial institutions or agents of financial institutions of any type; purchase or sale to customers of motor vehicles of any kind, vessels, aircraft, farm equipment or mobile homes; the practice of law, accountancy, or medicine; auctioning of goods; chartering or operation of ships, buses, or aircraft; gaming of any kind (other than licensed parimutuel betting at race tracks); investment advisory services or investment banking services; real estate brokerage; pawn brokerage; title insurance and real estate closing; trade union activities; and any other activities that may be specified by FinCEN. A business that engages in multiple business activities may be treated as a non-listed business so long as no more than 50% of its gross revenues are derived from one or more of the ineligible business activities listed in this paragraph (e)(8).
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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