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Bank Secrecy Act › FinCEN › Casinos

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Brownstein Hyatt Farber Schreck

Recent Enforcement Actions a Reminder of the Importance of BSA Compliance for Nevada Casinos

Brownstein Hyatt Farber Schreck on

Following a multiyear lull, the Nevada gaming industry has recently experienced a flurry of federal and state regulatory actions related to the enforcement of the Bank Secrecy Act. Just the past several months alone have seen...more

Ballard Spahr LLP

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

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The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”).  The Consent Order describes Lake...more

Brownstein Hyatt Farber Schreck

Federal and State Regulators Increase Scrutiny of Casino AML Practices

Brownstein Hyatt Farber Schreck on

Recent money laundering-related enforcement actions targeting casinos by both the U.S. Department of Justice (“DOJ”) and state regulators suggest increasing scrutiny of anti-money laundering (“AML”) compliance efforts within...more

Ballard Spahr LLP

Nevada Gaming Control Board Alleges Casino AML Failures Based on Wagering of Customers Involved in Illegal Bookmaking

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The Nevada Gaming Control Board (“Board”) recently filed a complaint (“Complaint”) against Resorts World Las Vegas casino (“Resorts World”), alleging that, despite repeated red flags, Resorts World’s Anti-Money Laundering...more

Foodman CPAs & Advisors

¿Cuándo Son Los Casinos Instituciones Financieras?

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De acuerdo con el IRS y FinCEN, los casinos con licencia para hacer negocios como casinos y que tienen ingresos brutos anuales de juego superiores a $1,000,000 son instituciones financieras sujetas a los requisitos de la Ley...more

Foodman CPAs & Advisors

When Are Casinos Financial Institutions?

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According to the IRS and FinCEN, Casinos licensed to do business as casinos and which have gross annual gaming revenues in excess of $1,000,000 are Financial Institutions subject to the requirements of the Bank Secrecy Act,...more

K2 Integrity

Mobile Sports Gambling and Sports Betting Risks

K2 Integrity on

Gambling is an industry that, like it or not, is inherently associated with risk. In fact, its very existence is based on participants willing to take chances with (usually) their own hard-earned money. These truths, as well...more

Blank Rome LLP

FinCEN Director Emphasizes AML Priorities for Casinos, Sports Wagering, Mobile Gaming, and Card Clubs in Las Vegas Speech

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As underscored in a recent speech by the director of the Financial Crimes Enforcement Network (“FinCEN”), compliance officers should ensure that their anti-money laundering (“AML”) programs are current with FinCEN’s...more

Bass, Berry & Sims PLC

Anti-Money Laundering Update: California Card Club Clubbed by FinCEN for AML Violations

Bass, Berry & Sims PLC on

Post at a glance: • FinCEN imposes $8 million penalty against California’s biggest and oldest card club • Club failed to implement and maintain an effective anti-money laundering (AML) program and failed to detect,...more

Fox Rothschild LLP

California Card Club Plagued By Allegations Of Criminal Activity Fined $8 Million For AML Violations

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Today the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it had fined a California card club, Artichoke Joe’s Casino, $8 million for numerous willful violations of the Bank Secrecy Act...more

Ballard Spahr LLP

2016 Year in Review: Money Laundering (Part One)

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2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

McGuireWoods LLP

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

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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

Bradley Arant Boult Cummings LLP

Don’t Roll the Dice: FinCEN Assesses Significant Penalties on Regulated Entity for Failing to Implement a Comprehensive AML...

Bradley Arant Boult Cummings LLP on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) imposed a civil money penalty of $12 million against a Nevada based casino, CG Technology, L.P. (CGT) for alleged violations of the Bank Secrecy Act...more

K2 Integrity

Upping the Ante on Casinos’ AML Compliance

K2 Integrity on

FinCEN focus requires major shift in gaming business practices - Which complex, global industry where billions of dollars exchange hands every day, and where high-net-worth customers park significant sums, is facing...more

Holland & Knight LLP

FinCEN Assesses Significant Penalty Against Casino for Bank Secrecy Act Violations

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The Financial Crimes Enforcement Network (FinCEN) assessed on July 15 a civil money penalty in the amount of $2.8 million against Hawaiian Gardens Casino Inc., d/b/a The Gardens Casino, for Bank Secrecy Act (BSA) regulatory...more

McGuireWoods LLP

Casino AML: FinCEN Fines Former Sparks Nugget Management $1 Million

McGuireWoods LLP on

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

McGuireWoods LLP

FinCEN Announces Caesars Penalty After Multiyear Investigation

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This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in...more

McGuireWoods LLP

Casino Forfeiture a Reminder that FinCEN’s Regulatory Oversight May Involve DOJ and Criminal Penalty

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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

The Volkov Law Group

Rolling the Dice: Casinos, FinCEN and AML Compliance

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FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more

McGuireWoods LLP

FinCEN Reasserts its Commitment to Casino Oversight and Enforcement

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In a recent post we described a number of steps taken over the last year by the primary federal regulator for casinos – the Financial Crimes Enforcement Network (FinCEN) – that should cause casino operators to have Title 31...more

McGuireWoods LLP

AML Compliance Developments in the Gaming Industry

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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

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