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Northern Marianas Islands Casino Hit with $75 Million Fine for Anti-Money Laundering Violations
A casino in the Northern Mariana Islands has been slapped with a hefty fine of $75 million by the Financial Crimes Enforcement Network (FinCEN) for willful and egregious violations of anti-money laundering laws. Hong Kong Entertainment (Overseas) Investments, Ltd., doing business as Tinian Dynasty Hotel & Casino, failed to implement an anti-money laundering program and allowed suspicious transactions to go unreported.
Casino’s Lack of Compliance
According to FinCEN Director Jennifer Shasky Calvery, the casino’s lack of compliance presented a real threat to the financial integrity of the region and the US financial system. The casino’s management failed to develop and implement policies and procedures to ensure compliance with anti-money laundering laws, and employees were not trained in reporting suspicious activity.
Investigation Findings
The investigation found that Tinian Dynasty accommodated patrons who wanted to conduct large cash transactions without reporting them. Undercover agents posing as customers requested that the casino not report their transactions, and the casino’s VIP Manager assured a Russian businessman that he could bring large amounts of currency without filing reports.
Additional Violations
The casino also failed to file thousands of required currency transaction reports and suspicious activity reports. A 2013 search of the casino turned up over 2,000 unfiled reports, with the Chief Auditor stating that filing them was a low priority because nobody noticed they weren’t being filed.
FinCEN’s Assessment
FinCEN’s assessment notes that Tinian Dynasty’s actions were “egregious” and “willful,” and that the casino’s management facilitated suspicious transactions and provided guidance on how to skirt anti-money laundering laws. The fine is one of the largest ever imposed by FinCEN, and it serves as a warning to other financial institutions in the region to prioritize compliance with anti-money laundering regulations.
Key Takeaways
- Tinian Dynasty Hotel & Casino was fined $75 million for willful and egregious violations of anti-money laundering laws.
- The casino failed to implement an anti-money laundering program, allowing suspicious transactions to go unreported.
- The investigation found that the casino accommodated patrons who wanted to conduct large cash transactions without reporting them.
- The fine is one of the largest ever imposed by FinCEN, and serves as a warning to other financial institutions in the region to prioritize compliance with anti-money laundering regulations.