Financial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance. FinCEN began 2017 by...more
Attributing observed deficiencies to a lack of a culture of compliance, FinCEN has again targeted a casino for willful violations of the anti-money laundering (“AML”) provisions of the Bank Secrecy Act (“BSA”). This time the...more
The civil money penalty was surprising for two reasons: first, that FinCEN would investigate and fine a casino unfamiliar even to analysts who cover the gaming industry, on an island chain few knew existed; and second, for...more
Executives of regulated entities often lament that fulfilling compliance obligations interferes with their ability to operate their business. However, an extensive (and extended) regulator investigation with the potential for...more
4/28/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Casinos ,
Chief Compliance Officers ,
Compliance ,
Enforcement Statistics ,
FinCEN ,
Gaming ,
SAR ,
Title 31 ,
Trump Administration