Lack of Anti-Money Laundering Program Nets Casino a $75 Million Fine

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) has levied the largest fine in its history — $75 million — against a casino for failing to have an anti-money laundering program in place, a violation of the Bank Secrecy Act (BSA).

The Tinian Dynasty Hotel & Casino, located in the Northern Mariana Islands, was assessed the penalty by FinCEN in early June 2015. The Northern Mariana Islands is a U.S. Commonwealth, and falls under the authority of FinCEN, which investigates casinos for BSA compliance. Casinos that operate in the U.S. are required to have anti-money laundering (AML) programs in place that include a system of internal controls, training for casino personnel, independent compliance testing and the designation of an individual to manage and monitor the program for compliance.

FinCEN investigators said that Tinian Dynasty incurred several BSA violations, including agreeing not to report the gambling activity of undercover agents to the IRS and showing the agents how to avoid filing Currency Transaction Reports (CTRs). Casinos are required to file CTRs for cash transactions of more than $10,000. According to FinCEN, the casino did not file CTRs because no one had noticed their failure to do so in the past.

In addition, FinCEN said that the most serious infraction was that Tinian Dynasty failed to have an AML program in place. None of the casino’s staff had delegated responsibility to ensure BSA compliance, nor did it have a process in place to detect suspicious transactions.

The previous highest casino fine from FinCEN was a $10 million penalty levied against Trump Taj Mahal casino in Atlantic City, NJ, earlier this year. The fine was also for failing to have an adequate AML program in place and failure to file CTRs.

The Cogdell Law Firm is a full service criminal litigation and appellate law firm. We provide client-focused representation at all stages of the process, whether our clients are seeking to avoid charges, have been charged, or are seeking reversal of a conviction on appeal. When results matter most, contact Dan Cogdell at

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) has levied the largest fine in its history — $75 million — against a casino for failing to have an anti-money laundering program in place, a violation of the Bank Secrecy Act (BSA).

The Tinian Dynasty Hotel & Casino, located in the Northern Mariana Islands, was assessed the penalty by FinCEN in early June 2015. The Northern Mariana Islands is a U.S. Commonwealth, and falls under the authority of FinCEN, which investigates casinos for BSA compliance. Casinos that operate in the U.S. are required to have anti-money laundering (AML) programs in place that include a system of internal controls, training for casino personnel, independent compliance testing and the designation of an individual to manage and monitor the program for compliance.

FinCEN investigators said that Tinian Dynasty incurred several BSA violations, including agreeing not to report the gambling activity of undercover agents to the IRS and showing the agents how to avoid filing Currency Transaction Reports (CTRs). Casinos are required to file CTRs for cash transactions of more than $10,000. According to FinCEN, the casino did not file CTRs because no one had noticed their failure to do so in the past.

In addition, FinCEN said that the most serious infraction was that Tinian Dynasty failed to have an AML program in place. None of the casino’s staff had delegated responsibility to ensure BSA compliance, nor did it have a process in place to detect suspicious transactions.

The previous highest casino fine from FinCEN was a $10 million penalty levied against Trump Taj Mahal casino in Atlantic City, NJ, earlier this year. The fine was also for failing to have an adequate AML program in place and failure to file CTRs.

The Cogdell Law Firm is a full service criminal litigation and appellate law firm. We provide client-focused representation at all stages of the process, whether our clients are seeking to avoid charges, have been charged, or are seeking reversal of a conviction on appeal. When results matter most, contact Dan Cogdell at (713) 426-2244 or info@cogdell-law.com.

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