Smarter, safer, faster — and built for Title 31 from the first line.
Solstice is player tracking and BSA/AML compliance for Washington house-banked cardrooms. Live MTL, CTR preparation, SAR workflow, WSGC packets — on the tablets your floor already has. The incumbent was last meaningfully updated in 2013. This was built for the rules you are under now.
No signup, no card, no install. Your own private floor in about eight seconds.
The actual product· not a mockup · a live rating slip, open mid-shift
still accrues to a day total
+ revoked write grant
→ fixes ship in days
→ the numbers always agree
The three things federal law
assumes you already have.
Past $1M in annual gaming revenue, a cardroom is a financial institution under the Bank Secrecy Act — for a Washington house-banked room, that's settled by the end of January. The examiner will not ask whether you keep these. They will ask to see them. And they are exactly where the incumbent has nothing.
Live currency log
Real-time aggregation per patron, per gaming day, per property — cage and tables in one running total, with proximity alerts before a threshold arrives instead of after.
Form 112 preparation
Triggers strictly over $10,000, routes to a supervisor queue, pre-fills what it knows, and counts the 15-day filing window down in the app so nothing goes quietly late.
Pattern review & narrative
Suspicious-pattern review with a Part V narrative your supervisor edits and approves. With the AI add-on the draft is written for you; without it, the narrative is templated.
$600 to the CTR line
Four slips. One patron-day.
Two thousand five hundred dollars, then two thousand, then twenty-nine hundred, then two thousand again. On four separate slips not one of them is remarkable, and nobody on the floor has a reason to look twice.
Aggregated — which is the entire purpose of a currency transaction log — they are a $9,400 day sitting $600 under a federal filing obligation. Your floor should know that before the fifth buy-in, not when someone reconciles the drop tomorrow.
That aggregation is the thing the incumbent system does not do at all.
What that means in practice
- Deadlines tracked in-app — CTR windows, monthly records, retention clocks.
- Five-year AML records, hash-chained and append-only, producible on demand.
- Name refusals logged with timestamp, employee and session, in one tap.
- Self-exclusion checked at enrollment and re-checked on a schedule.
- Cardless cash still aggregates to a day total — and is refused, not quietly written, at or above the identity threshold.
And what it does not do — plainly
- CTR is prepare, not transmit. Solstice fills and tracks the form; your officer uploads it at the FinCEN portal.
- Aggregation is per property. There is no cross-venue rollup today.
- Table figures are keyed by your supervisors. Nothing is sensed or counted automatically — that boundary is deliberate, and it is why there is no lab review.
It audits its own books
every night.
Every buy-in writes to four places — the cash ledger, the table drop, the MTL, and the player’s own slip. Most systems assume those four agree forever. Solstice checks, nightly, and tells someone when they don’t.
Twenty-eight integrity checks run per property per day, covering unfiled CTRs past their window, expired gaming licences, retention violations, orphaned seat cash, and ledger-vs-drop reconciliation. A failure raises an alert on the compliance feed — it does not sit in a log nobody reads.
AI that drafts. Never decides.
Every number, every tier and every filing obligation in Solstice is computed by deterministic code, and is identical whether you take the AI layer or not. The AI writes prose about those numbers — on inference that runs either inside the Solstice perimeter or on your own hardware, whichever you choose. Never at a third-party AI provider.
The AI layer is switched on per property, on request — it is off unless you ask for it. We size the inference for your floor and validate your chosen model against our evaluation set before it goes live. Everything else on this page runs without it.
SAR narrative drafting
A Part V draft your supervisor edits, approves, or discards. The facts come from the deterministic record; the model only writes them up in prose a reviewer can read.
Compliance Findings Engine
A nightly advisory pass that surfaces the small set of discretionary, gray-zone patron-days worth a human look — each with deterministic evidence and citations. It stays silent on clean mechanical CTR crossings; those belong to the state machine.
Natural-language search
Ask the floor a question in plain English instead of building a query. The parse runs on whichever inference you chose, so a patron’s name never becomes someone else’s training data.
◆ The AI is optional by design. If the model is slow, unavailable, or returns something invalid, the finding simply stands without its summary and the compliance record is unaffected. Nothing in your regulatory obligation depends on a model being up.
The compliance core never changes.
You choose how much of the property runs on it.
Every tier is the complete cardroom — player tracking and the full Title 31 stack. Tiers differ by how far past the pit the system reaches. The AI layer is a separate decision entirely, and it sits on any tier.
| Capability | Tier 1
Cardroom
The floor, complete. Everything a house-banked room needs to operate and stay compliant. |
Tier 2
Venue
Adds the outlets. Comps earned on the floor spend at your own restaurant and retail. |
Tier 3
Enterprise
Adds the back office. One system from the pit to the general ledger. |
|---|---|---|---|
| Cardroom & compliance | |||
| Player tracking, floor map, ratings, comps | ✓Included | ✓Included | ✓Included |
| Live MTL · CTR preparation · SAR workflow | ✓Included | ✓Included | ✓Included |
| Immutable 5-year audit trail · WSGC packets | ✓Included | ✓Included | ✓Included |
| Nightly integrity & reconciliation checks | ✓Included | ✓Included | ✓Included |
| Connected verticals | |||
| Point of sale — comps redeemable at F&B and retail | —Not included | ✓Included | ✓Included |
| Staff scheduling, HR and timekeeping | —Not included | ✓Included | ✓Included |
| Inventory and purchasing | —Not included | ✓Included | ✓Included |
| Finance, general ledger and procurement | —Not included | —Not included | ✓Included |
| Analytics and document intelligence | —Not included | —Not included | ✓Included |
| Best fit | |||
| Typically | A cardroom, on its own | A property with a kitchen, bar or retail | An operation that wants one back office |
SAR narrative drafting
A Part V draft your supervisor edits, approves, or discards. The facts come from the deterministic record; the model only writes them up.
Findings summaries
Plain-English annotation on the nightly Compliance Findings queue. The findings and their evidence are deterministic and run on every tier — with or without AI.
Natural-language search
Ask the floor a question in plain English instead of building a query.
We run the model on private, tenant-scoped infrastructure inside the Solstice perimeter. Nothing for you to buy, install, patch or keep running.
You run the model on hardware at your property, joined privately to your tenant. You own the box and the upgrade cycle; we point Solstice at it.
The same boundary applies either way. Solstice refuses to talk to a model on a publicly routable address — the check runs at startup and fails closed, so there is no configuration, accidental or otherwise, in which a patron’s details are sent to a third-party AI provider. The choice above is about who operates the hardware and where the data physically sits, not about whether the boundary holds.
◆ The comp loop is the reason to go past Tier 1. A comp earned at the table settles as an authorised tender at your own point of sale — the player’s identity never enters the POS, and the value lands back in your ledger instead of a competitor’s. No player-tracking vendor in this market can close that loop, because none of them own the register.
Your twelve years of players
come with you.
The reason rooms stay on software from 2013 is the migration, not the software. Solstice imports your existing player database directly — records, card numbers, history and the ID photos on file — into your own tenant, with a reconciliation report you check before anyone signs in.
Nobody re-keys a card file. Nobody loses a photo.
Walk a floor before you talk to anyone.
- One click, no sign-up. Runs in your browser, installs as an app on any tablet.
- You get a private cardroom. Fictional players, isolated to your session.
- Do real work. Enroll a player, open a rating, take a buy-in, and watch the currency ladder climb toward the CTR line.
Will Spinden
Solstice is built and supported by one person who answers the phone. That is a fair thing to ask about, so here is the plain version: you get direct access to the person who wrote it, fixes ship the same week, and there is no support tier to escalate through.
Before you ask.
Do I have to buy the AI to get the POS integration?
No, and that is deliberate. Wanting your restaurant on the same system has nothing to do with wanting a model to draft narratives, so they are priced as two separate lines. Take Tier 2 with no AI, or Tier 1 with AI — both are ordinary configurations, not exceptions we make.
Does the AI see my players’ personal information?
Patrons are replaced with per-property tokens before anything reaches a model, with a scrubber behind that as a second line. Beyond that it is your call where the model lives: we host it on private infrastructure inside the Solstice perimeter, or you run it on your own hardware and patron data never leaves your building. Either way Solstice refuses a publicly addressed model host at startup, so no patron data is sent to a third-party AI provider in any configuration. And if you do not take the AI add-on, no model runs against your data at all.
Can the AI change a compliance number or dismiss a finding?
No. Deterministic code owns every figure, every tier and every filing obligation; the model writes prose about them. Findings are ranked, never suppressed — nothing is auto-dismissed or hidden, a human confirms or dismisses each one, and findings can never be deleted. Every AI-assisted line is labelled “Operational estimate for internal review. Not an official record.”
Does this need WSGC approval to install?
No. The Commission’s Electronic Gambling Lab determined Solstice is not gambling equipment under WAC 230-03-200 — it is player-tracking and BSA/AML software operated by your staff. No lab submission, no certification wait, and no re-approval when we ship an update, which is why improvements reach your floor continuously. It holds because nothing connects to a table and nothing is counted automatically.
Does the CTR actually get filed?
Not automatically, and we would rather say so on the website than on day 14 of your 15-day window. Solstice detects the crossing, prepares the form, routes it for supervisor review, and tracks the deadline. Your officer performs the upload at the FinCEN portal.
What happens to my player data — and my ID photos?
They come with you, photos included. Your data lands in a tenant only you can reach, encrypted at rest with keys scoped to your property. If you ever leave, you get an export.
Can we add a tier or the AI layer later?
Yes, and nothing re-migrates. The compliance core is the same on every tier, so adding the point of sale, the back office, or the AI layer is a configuration change against the data you already have — not a new install and not a re-import. The AI layer in particular is enabled per property on request, so starting without it costs you nothing and closes no door.
What does it cost?
Per-property subscription priced against your table count and tier, with the AI layer as a separate line if you want it — no per-seat licensing, no charge for the migration. We will quote you on the call.
Bring Solstice to your floor.
A real person reads it and replies. We will walk the demo on your own numbers and tell you honestly which tier fits.