Anti-Money Laundering Laws in Northern Mariana Islands Lead to Record Forfeiture
Largest Forfeiture Ever Collected in the Commonwealth
The Office of the United States Attorney for the Northern Mariana Islands has secured a non-prosecution agreement with Hong Kong Entertainment (Overseas) Investments Ltd., doing business as Tinian Dynasty Hotel & Casino. Under the terms of the agreement, the casino will forfeit $3,036,969.12, the largest forfeiture ever collected in the Commonwealth.
Cooperation and Compliance Required
As part of the agreement, Tinian Dynasty Hotel & Casino must:
- Fully cooperate with ongoing criminal investigations
- Comply with federal reporting and regulatory requirements
- Reserve the right to rescind the agreement and initiate criminal proceedings if the casino fails to comply with any provision
Case Details
The case involves allegations that the casino failed to adequately report cash transactions exceeding $10,000, in violation of anti-money laundering laws. According to court documents:
- The casino did not fully identify and disclose all individuals whose gambling activities triggered reporting requirements
- It is estimated that the casino failed to report over $138 million in cash transactions between 2009 and 2013
Undercover Investigation Reveals Non-Compliance
The investigation found that casino employees assured undercover IRS agents that they could gamble with large amounts of currency without triggering reports. The agents then conducted currency transactions totaling over $450,000, but a required Currency Transaction Report was never filed.
Importance of Compliance
“This case highlights the importance of complying with anti-money laundering laws,” said US Attorney Alicia A.G. Limtiaco. “Financial institutions that fail to adequately know their customers and screen transactions for suspicious activities can be exploited by criminals.”
Effective Anti-Money Laundering Programs Required
Under federal law, financial institutions and businesses are required to implement and maintain effective anti-money laundering programs to detect and report suspicious activity. The Bank Secrecy Act requires casinos with annual gaming revenue exceeding $1 million to file Currency Transaction Reports for transactions involving more than $10,000 in cash.
Continued Partnership
The US Attorney’s Office will continue to partner with the IRS CI and other agencies to ensure compliance with anti-money laundering laws and regulations.