From Title 38-VETERANS' BENEFITS PART III-READJUSTMENT AND RELATED BENEFITS CHAPTER 31-TRAINING AND REHABILITATION FOR VETERANS WITH SERVICE-CONNECTED DISABILITIES. 306, provided that: "Section 5318(i) of title 31, United States Code, as added by this section, shall take effect 270 days after the date of enactment of this Act [Oct. Counterfeit Currency Prevention 8. L. S. Insights into the reporting requirements of Title 31, what forms to use, and the definition of a "structured" transaction. S. This course is an introductory level training for gaming regulators, commissioners, tribal leadership, and gaming industry personnel interested in the responsibilities of regulating a tribal government gaming facility. L. Among non-bank financial institutions, casinos top the list of businesses that federal regulators are scrutinizing for evidence of money laundering — and it’s not hard to see why. S. Code, Chapters 31, “Training and Rehabilitation for Veterans with Service-Connected Disabilities” – This law addresses the program that provides for services and assistance necessary to enable veterans with service-connected disabilities to achieve maximum independence in daily living and, to the maximum extent feasible, to. 30, 1986, 100 Stat. Pub. L. ) of former Title 31, Money and Finance, which was repealed and reenacted as subchapter II of chapter 53 of Title 31, Money and Fi-nance, by Pub. Two of the most popular strategies for circumventing CTR reporting are structuring and minimal gaming. Provi-sions relating to reports on internal accounting and ad-ministrative control systems are restated in section 3512(d)(2) and (3) of this title. Please tell us about your training. Internal policies, procedures, and controls; 2. 754 (a) (less form of certificates of indebtedness and Treasury bills, finality) 3104. C. S. Did you get any RECOGNITION OF PRIOR LEARNING towards your training such as subject exemptions, course credits. Title 31 Hotel--training guidelines. (2) To meet the requirements of paragraph (1), the sleeping areas and latrine areas. —Before the end of the 6-month period beginning on the date of enactment of this Act [Sept. If you have questions regarding Rule 31, contact our team at [email protected] A withdrawal is a voluntary act in which an individual forfeits all rights to a specific application. Reduce risk in casino operations with Title 31 and Anti-Money Laundering training compliance. Draft written response for internal and external Title 31 audits. 31 U. Pub. 116–283, div. C. 8), regarding license prerequisites and to license renewals. 17 The training was at the right level of difficulty for me. With this training, operators not only maintain compliance, but remain well-versed in the ever-changing laws and regulations of Title 31 anti-money laundering. C. We provide lost-cost online testing and training modules to accommodate casinos of all sizes that. Match. 102–550, title XV,. ONLINE TRAINING PROGRAMS. The term includes each program for which the Secretary or the Department has administrative responsibility under the Department of Education Organization Act [20 U. Title 31 AML Conference The 13th Annual National AML Las Vegas Conference & Expo at Caesars Palace Las Vegas may be over, but learning and growth never stops. Government Publishing Office, §3321. Our support team assists with assigning the. 13, 1982, 96 Stat. Improving Government Program Performance. C. The Dowling Advisory Group provides casinos with expertise in conducting independent testing of Title 31 programs, creating and evaluating risk assessments and related programs. All enlisted and officer Marines are assigned a four-digit code denoting their primary occupational field and specialty. 16, 2016, 130 Stat. (commonly referred to as the 'Economy Act'), or any other provision of such title may be construed to prevent or restrict the Chief Administrative Officer of the House of Representatives from placing orders under such. EFFECTIVE DATE OF 2009 AMENDMENT Amendment by section 1001(e)(2) of Pub. 31-10-102. AGA commissioned a detailed study by Ernst & Young which was released in 2016 demonstrating the great strides the Casino. Casino Essentials delivers more than 150 engaging online training courses, including Title 31, Responsible Gaming, Sexual Harassment, and a full Coronavirus series focused to get your employees back to work safely. Training (other than. 9:00am-12:00pm - Class Begins. Displaying title 31, up to date as of 11/14/2023. Did you get any RECOGNITION OF PRIOR LEARNING towards. U. No. Instructor: Armen Khachadourian Product ID: 703574 Training Level: Intermediate Duration: 60 Min ; This webinar will review current requirements of the Bank Secrecy Act, why to comply, how to comply, reporting techniques and current positions by the IRS and FinCEN. . 753 (d) (last sentence related to 31:771) 3122. C. Title 31 Definitions. Reduce risk in casino operations with Title 31 and Anti-Money Laundering training compliance. 95. the consequences of failing to comply with Title 31 requirements. 1980, to August 31, 1984. Strongly Disagree Disagree. L. L. CHAPTER 9—ADJUSTMENT OF DEBTS OF A MUNICIPALITY (§§ 901 – 946) CHAPTER 12—ADJUSTMENT OF DEBTS OF A FAMILY FARMER OR FISHERMAN WITH REGULAR ANNUAL INCOME (§§ 1201 – 1232) CHAPTER 13—ADJUSTMENT OF DEBTS OF AN INDIVIDUAL WITH REGULAR INCOME (§§. Title 31 Online Training Program – Casino Essentials – Title 31 Training and More. required. 250. The employee shall receive additional training if the employee is reassigned from a facility that houses only male inmates to a facility that houses only female inmates, or vice versa. 97–258, §1, Sept. S. Salary offset means a type of administrative offset to collect a debt owed by a Federal employee from the current pay account of the employee. S. I would also like to thank Casino Essentials for hosting this Title 31 conference and inviting me to speak today. * This title has been enacted as positive law. Staff commentaries § 5330. 1/7/2021 What Title 31 Compliance Means for Casino AML Training Programs. 00 Downloadable file is for usage in one location only. —The term ‘financial in-stitution’— ‘‘(A) has the meaning given the term in section 5312 of title 31, United States Code; and ‘‘(B) includes— ‘‘(i) an electronic fund transfer network; and allows financial institutions to file reports required under subchapter II of chapter 53 of title 31, United States Code, chapter 2 of Public Law 91–508 [probably means chapter 2 (§§ 121 to 129) of title I of Pub. (o) (2), is subtitle B (§§511–542) of title V of Pub. Login below to get started. —Before the end of the 6-month period beginning on the date of enactment of this Act [Sept. 1381, provided that: "The Secretary of Defense shall establish policy and promulgate guidelines to ensure civilian and military law enforcement personnel charged with security functions on military installations shall receive Active Shooter Training as described in finding 4. Title 31 of the Bank Secrecy Act requires all casinos who have a gross annual gaming revenue of at least $1 million to draft and implement a written training program that ensures compliance with the law’s anti-money laundering regulations. 31-5-102(a)(lxi)(E) and any motor vehicle meeting the criteria of this subparagraph and not otherwise defined in this section; (N) "Street rod" means a motor vehicle that: (I) Is a 1948 or older vehicle, or the vehicle was manufactured after 1948 to resemble a vehicle manufactured before 1949; and (II) Has been altered from the1. Government Publishing Office, Statutory Notes and Related Subsidiaries Enacting Clause. L. 38 U. L. What is Title 31 intended to prevent? MONEY LAUNDERING. Publication Title: United States Code, 2006 Edition, Supplement 5,. Click the card to flip 👆. The instructors we have assembled for our conferences are experts in the Bank Secrecy Act, sanctions regulations, and illicit finance typologies. Title 31 Testing, LLC has been providing Casino Training, Testing, Consultation and Risk Assessments for the gaming industry since 2008! Our training programs have been used across the United States, in Commercial Gaming, as well as in Indian Country. ONLINE TRAINING PROGRAMS. The term ‘trainer’ refers to trainers, teachers, lecturers or instructors from your training organisation. Learn. In short, Title 31 requires banks and other financial institutions, including casinos, to comply with recordkeeping and reporting requirements. 22(b)(1)) [Financial institutions other than casinos]; 31 CFR §1021. C. 26, 2001], whether or not final regulations are issued under paragraph (1) [set out below], and the failure to. Code § 5321 - Civil penalties. "(1) allows financial institutions to file reports required under subchapter II of chapter 53 of title 31, United States Code, chapter 2 of Public Law 91–508 [probably means chapter 2 (§§121 to 129) of title I of Pub. The program is part of a law enacted by Congress under Title 38 Code of Federal Regulations, Chapter 31. C. Josh Peukert, CFE, CIA – Manager Title 31 of the United States Code outlines the role of the money and finance in the United States Code. 10 U. 95. 877 . 24 terms. With Vector Solutions, your organization can have confidence in providing an innovative casino training. L. Code: Title 11. ( d) Additional rules for internet based training courses. Ord. ( c) An employee who is excepted under paragraph (b) of this section is eligible to receive premium pay in accordance with the. 44(a). Solutions. Learn more. Pursuant to an order entered by the Tennessee Supreme Court on February 13, 2023, Tennessee Supreme Court Rule 31 (14) (g) was amended to change the number of required training hours necessary to become a Rule 31 listed family mediator with a domestic violence designation. 99, 40 Stat. S. Gaming is still largely a cash business, after all, and it’s not unusual for a. Lauren Melcher is the operations manager for Vector Solutions, a leader in eLearning and performance support, providing award-winning SaaS solutions. CASH OUT – The amount of currency paid out by a casino. Section 1. 1951 et seq. Explore the latest updates, articles, and other strategic guidance for the pandemic’s impact on your industry. Your feedback plays an important role in developing the quality of your education. Casino Essentials, a Vector Solutions brand, is the leading SaaS provider of Title 31 & AML (anti-money laundering) compliance training and eLearning solutions for the Gaming Industry. 16, 2016, 130 Stat. 91–508 (12 U. [12 U. Section 321 - Training with friendly foreign countries: payment of training and exercise expenses (a) TRAINING AUTHORIZED. Section 106. Costs of training and education that are related to the field in which the employee is working or may reasonably be expected to work are allowable, except as follows: ( a) Overtime compensation for training and education is unallowable. L. Financial Crimes Enforcement Network. Casinos: Title 31 compliance is just the beginning of better due diligence. 310-1029. As always, the LIMRA refresher training provides an important review. We now offer over 100 online courses. Counting mail ballots. 876, provided that: "Nothing in section 1535 of title 31, U. Except as provided in Section 2 of this Order, the Office of Personnel Management is hereby designated and empowered to exercise the authority vested in the President by Section 4102 (a) (2) (B) of Title 5, United States Code, to designate individuals appointed by the President for training under Chapter 41 of Title 5, United States. 693 Chapter VIII—Office of Investment Security, Department of the. 10 Administration. If you have a service-connected disability that limits your ability to work or prevents you from working, Veteran Readiness and Employment (formerly called Vocational Rehabilitation and Employment) can help. Additionally, to help casinos of all sizes maintain Title 31 compliance and satisfy training requirements, JOSEPH EVE created JE University, a web-based training program. Pub. (IRM 4. L. False: the Civil penalties can be over $25k per violation. S. ALTA® members search, review and insure land titles to protect home buyers and mortgage lenders who invest in real estate. A Casino Employee's Introduction to the Office of Foreign Assets Control. 330. 101 refers to title 31, part 500, section 101. 22 terms. Promotion of employment. Remember, a grade of less than 80% is failing and you only have 3 tries to pass the test. The United States Marine Corps Military Occupational Specialty (MOS) is a system of categorizing career fields. WebCE offers custom casino training solutions and casino compliance. The text of 31:951(b) is omitted as unnecessary because of laws vesting authority in the commission, board, or other group of individuals and for consistency in the revised title and with other titles of the United States Code. Must have successfully completed Title 31 training. Learn More. Must be a self-starter, motivated, versatile and responsible. 26, 2001, 115 Stat. )], or section 21 of the Federal Deposit Insurance Act [12 U. 3 of the document. United States Code, 2021 Edition Title 31 - MONEY AND FINANCE Front Matter From the U. Partner. , Multiple transactions are tracked at _____or more for a single transaction or aggregate transactions. 751 Chapter VIII—Office of Investment Security, Department of the. Metadata. "(1) In general. Pub. Under 2 CFR 200. §§ 1029. It can be tough finding the best options for your casino’s Title 31 and AML compliance training requirements. 2. Purchase Options . Challenges. Question Title. 31, 2008, see section 1001(f) of Pub. A critical review of existing models of practice for long-term athletic development is. Title 31 - It's NOT Complicated. Casinos and card clubs are subject to the program requirements. • Developed and conducted annual Title 31 training for 75+ personnel, including management personnel. - Maintain gaming floor, equipment and tables in clean, neat, and work safe condition. L. 31. Vocational Counseling. 23, 1992]; or. 4 CHAPTER VIII - OFFICE OF INVESTMENT SECURITY, DEPARTMENT. Submission of this certification is a prerequisite for making or entering into this transaction imposed by section 1352, title 31, United States Code. $19. Effective Date. To return to the beginning of the SAR training module, click here. L. Casinos: Title 31 compliance is just the beginning of better due diligence. the initiation or receipt of a covered Federal action, or a material change to a previous filing, pursuant to title 31 U. 37, a practitioner will be presumed to have exercised due diligence for purposes of this section if the practitioner relies on the work product of another person and the practitioner used reasonable care in engaging, supervising, training, and evaluating the person, taking proper account of the nature of. Administration of education program. Title 26 & Form 8300 for Non-Casino Departments 6. Normally, Title 32 orders are for natural disasters, while Title 10 orders are for national defense. Title 31 Introduction Overview* 2. Lawrence Seaway Development Corporation. 91–508 to the Code, see Tables. You will be redirected to the Course Information page. 210 - Anti-money laundering programs for dealers in precious metals, precious stones, or jewels. This program—also known as Chapter 31 or VR&E—helps you explore employment options and address education or training needs. 31 U. C. Pub. This online training program is available to all University of Pittsburgh faculty and staff to help you identify, avoid, and report wrongful behaviors. Financial Crimes Enforcement Network (FinCEN) FinCEN develops answers to Frequently Asked Questions to assist in. BSA 13 Office of Foreign Asset Control OFAC. C. 91–508 (12 U. 32 U. L. Title 31; SUBTITLE IV; CHAPTER 53; SUBCHAPTER II; Quick search by citation: Title. Chapter VII—Federal Law Enforcement Training Center, Depart-ment of the Treasury. Correctly applying the Bank Secrecy Act (BSA), or Title 31, and its regulations to your gaming entity can be a difficult and confusing process. The filing of a form is required for each payment or agreement to make payment to any lobbying entity for influencing or attempting to influence an officer or employee of any agency, a Member ofProvide for education or training of appropriate personnel,. * 18 The amount of work I had to do was reasonable. The words “for transportation” are omitted as surplus. (1) establish performance goals to define the level of. C. 31 U. Casino Essentials, a Vector Solutions brand, is the leading SaaS provider of Title 31 and AML (anti-money laundering) compliance training and eLearning solutions for the gaming industry. What constitutes "Identification" under Title 31? (1) VALID PHOTO ID; (2) SS#, TAX ID#, or EIN#; (3) LEGAL NAME & PHYSICAL ADDRESS; (4) DATE OF BIRTH. Reg. § 3116. 100 (hhh) rather than the definition of “United States” in. We now offer over 100 online courses. $200,000 with respect to a transaction valued at $100,000 or more but less than $200,000; 7. The training. S. Bank Secrecy Act (BSA), Title 31, Compliance. 31 CFR Chapter X is organized by generally applicable regulations and by industry-specific regulations. Enhanced Training, Examinations, and Referrals by Banking Agencies. Title 31. Pub. 1] Toggle Land Title and Survey Authority Fees [§31. ALTA® members search, review and insure land titles to protect home buyers and mortgage lenders who invest in real estate. L. (iii) who, after attaining the age of eighteen years and until completion of education or training (but not after attaining the age of twenty-three years), is pursuing a course of instruction at an approved educational institution;. It offers a range of services, including: Interest and aptitude testing: This is a test that helps determine aptitude in civilian job fields. Casino are required to report transactions in currency that have the same directional flow, and. Displaying title 31, up to date as of 9/26/2023. ), and in furtherance of the purposes of Chapter 41 of title 5, United States Code, the Government Employees Training Act of 1958 (Public Law 85–507 [see. (1) Each casino shall develop and implement a written program reasonably designed to assure and monitor compliance. I continue to train, update and maintain our BSA/Title 31 program to keep it current with FinCen requirements. 16, 2016, 130 Stat. Question Title. Training is coordinated within the United States Government, which leverages multilateral organizations and bodies and international financial institutions to internationalize the conveyance of technical assistance. An FAA-issuedCHAPTER 3—PERSONNEL (§§ 301 – 335) CHAPTER 5—TRAINING (§§ 501 – 509) CHAPTER 7—SERVICE, SUPPLY, AND PROCUREMENT (§§ 701 – 717) CHAPTER 9—HOMELAND DEFENSE ACTIVITIES (§§ 901 – 908) Table Showing Disposition of All Sections of Former Title 32. ALTA® is headquartered in Washington, DC. It is a collection of Session Laws (enacted by the Legislature, and signed by the Governor, or enacted via the initiative process), arranged by topic, with amendments added and repealed laws removed. Title 31 Testing, LLC has been providing Casino Training, Testing, Consultation and Risk Assessments for the gaming industry since 2008! Our training programs have been used across the United States, in Commercial Gaming, as well as in Indian Country. Answer. ( b) Compliance programs. Ms. 1. L. Processing of mandatory declassification review requests. Pub. —The Secretary of the Treasury, in consultation with the Attorney General and Federal, State, Tribal, and local law enforce-. S. (2) “Child” means a person who has not yet attained the child’s eighteenth birthday. C. * This title has been enacted as positive law. This document covers the year 2011 and includes the section 720(b) on the reports and recommendations of the Comptroller General. We now offer over 100 online courses. Obtain a comprehensive risk assessment with an analysis and review of your casino’s BSA/Title 31 compliance program. Counterfeit Currency Prevention 8. - procedures - training - definitions. Title 31-Training Guidelines Quiz. 8/14/2023 Tribal gaming grows for the third consecutive year 8/22/2022 Tribal gaming. com. 8 ) If apparent BSA violations are found which appear to meet the referral criteria,. Get Form Show details. 306, provided that: "Section 5318(i) of title 31, United States Code, as added by this section, shall take effect 270 days after the date of enactment of this Act [Oct. L. Veterans’ Advisory Committee on Rehabilitation § 3122. In subsection (c), before clause (1), the word "services" in 31:82c(last proviso) is omitted as surplus. The words “of the United States” are omitted as unnecessary. Tara_Gandy3 Teacher. Provide for on-going education and training of appropriate persons concerning their. This training website will provide you with all of the information needed to pass the Title 31 exam during your employment at any of the three Red Lake gaming properties. . Because there are many types of suspicious activities, it is required that casino personnel receive Title 31 training to avoid penalty and remain compliant. CTR. S. 311 (formerly 31 CFR 103. If you fail to take the appropriate steps your company could face serious. Federal Law Enforcement Training Center, Department of the Treasury. 31-10-913. Upon completion of this course, the individual should know and understand: the money laundering process. C. , The purpose of the MTL is to identify guests which have a transaction(s) with same _____ _____which total. Definitions. C. Pub. g. Get the solution that enables your casino staff to receive compliance training when and where it’s convenient for them. Displaying title 31, up to date as of 11/14/2023. S. capacities of a child support obligor by cooperating with the appropriate state agencies to provide the necessary training, job upgrading, or both. Code § 1535 - Agency agreements. Share. S. 2 See 31 USC § 5324(d). The GLI University® Online Compliance Collection covers Title 31 training, Anti-Money Laundering training and many. RECORDED TRAINING. Taking into account the gaming industry’s 24/7 environment, the BSA/AML Professional Development Program is self-paced and available on-demand in. It is also possible to subscribe to the eCFR changes from single or multiple agencies. Title 31/OFAC Title 31 of the U. We provide lost-cost online testing and training modules to accommodate casinos of all sizes. and training in the use of, technology to detect and prevent financial crimes and terrorism within and without the United States, $8,000,000. SYNK31 is an industry award-winning system focused on efficiency, speed, connectedness, and consistency—all of which are key to enduring property compliance. $229. 4589, 4590, 4597, 4603, 4623, added items 5323 and 5333 to 5336 and struck out former item 5323 “Rewards for informants” and item 5328 “Whistleblower protections”. An applicant for a pilot school certificate or provisional pilot school certificate may request approval for the training courses specified under § 141. Part II of the Act is classified generally to subchapter II (§8221 et seq. The Nonadmitted and Reinsurance Reform Act of 2010, referred to in subsec. 23, 1992]; or. Title 31 Testing, LLC has been providing Casino Training, Testing, Consultation and Risk Assessments for the gaming industry since 2008! Our training programs have been used across the United States, in Commercial Gaming, as well as in Indian Country. Title 31: Money and Finance: Treasury List of Subjects revised as of October 1, 2023. 157, 676). . Learn more. Financial Crimes Enforcement Network (FinCEN) FinCEN develops answers to Frequently Asked Questions to assist in complying with the responsibilities under the Bank Secrecy Act (BSA). The LIMRA 2023 AML refresher course aims to put a dent in that number and protect companies, financial professionals, and customers. L. Enhanced Training, Examinations, and Referrals by Banking Agencies. Title 31 for Executives & Compliance Professionals 5. 343, 61 Stat. L. Personnel training,. 400. About Vector Solutions Vector Solutions for Casinos has been in the industry for over 10 years, as the leading Saas provider for online Title 31 and Anti-Money laundering training, helping clients meet federal mandates for reporting certain currency transactions to uncover money laundering and other financial crimes. 1 Subtitle A - Office of the Secretary of the Treasury PARTS 0 - 50:. Title 31 SAR Incident Scenarios & Reporting* 4. Today, more than 200,000 casino employees rely on Vector Solutions Casinos to streamline compliance. Purchase Now. Employee Training . —Each Federal ex-Performance plans. Structuring. Chapter VII—Federal Law Enforcement Training Center, Depart-ment of the Treasury. 31:1: Money and Finance: Treasury--Volume 1: 31:1. 200 General. A, title III, §367, Dec. United States Code, 2010 Edition Title 31 - MONEY AND FINANCE SUBTITLE I - GENERAL CHAPTER 3 - DEPARTMENT OF THE TREASURY SUBCHAPTER I. Pub. In subsection (b), before clause (1), the words “On and after June 1, 1942” are omitted as executed. True or False: A casino is required by federal law to have a program in place to prevent and report potential money laundering. Legislative history [ edit ] The title was codified September 13, 1982 as "Money and Finance", Pub. 28, 1992,. ( 1) Each casino shall develop and implement a written program reasonably designed to assure and monitor compliance with the requirements set. Title 31 was last amended 9/22/2023. You will receive a final written report that details the overall condition, risks. —The Financial Crimes Enforcement Network established by order of the Secretary of the Treasury (Treasury Order Numbered 105–08, in this section referred to as “FinCEN”) on April 25, 1990, shall be a bureau in. (1) “Abuse” or “abused child” is as defined in § 901 of Title 10. 64(a. Because the $10,000 per gaming day CTR threshold is part of the Bank Secrecy Act, a criminal may seek to evade being recorded on a CTR by breaking a transaction over $10,000 into multiple smaller transactions, which is known as structuring. §5334 TITLE 31—MONEY AND FINANCE Page 474 (e) GUIDANCE. Pub. 23,. 1554, provided that: "The amendment made by subsection (a) [amending this section] shall apply with respect to a course of education or training pursued by a veteran who first begins a program of rehabilitation under chapter 31 of title 38, United States Code, on or after the. VerDate Mar<15>2010 17:05 Aug 17, 2013 Jkt 229126 PO 00000 Frm 00004 Fmt 8092 Sfmt 8092 Q:\31\31V3. Tooltip Public Law (United States) 97–258 , 96 Stat. If you fail the exam twice, please. Learn about eligibility requirements for Veteran Readiness and Employment (VR&E)—formerly called Vocational Rehabilitation and Employment. If you’re a service member or Veteran and have a disability that was caused—or made worse—by your active-duty service and that limits your ability to work or prevents you from working, you may be. . tara_moore39. Pub. Flashcards. Employee Training . Bank Secrecy Act (BSA), Title 31 of the Code of Federal Regulations Casinos are cash intensive businesses that can offer a broad array of financial services, such as: • Deposit or credit accounts • Facilities for transmitting and receiving funds transfers directly from other institutions • Check cashing and currency exchange services "(1) allows financial institutions to file reports required under subchapter II of chapter 53 of title 31, United States Code, chapter 2 of Public Law 91–508 [probably means chapter 2 (§§121 to 129) of title I of Pub. Monetary Instrument Log (MIL) a chronological record of monetary instruments issued or cashed with face value of $3,000 or more. the head of the agency decides ordered goods or services cannot be provided by. Required training programs and attributes; Involvement of depository and lending financial institutions in maintaining your Casino’s Title 31 Compliance; Independent testing of Title 31 compliance requirements Instructors: Sheryl Ashley, CIA, CFE, FCPA, CPA – Partner. Inventive educational experiences that engage and empower. of this appendix with respect to a transaction valued at $200,000 or more.