FINCEN Imposes $75 Million Penalty on Tinian Dynasty for Violating Anti-Money Laundering Regulations
Introduction
The Financial Crimes Enforcement Network (FinCEN) has imposed a significant penalty on Tinian Dynasty, a casino operator in the Northern Mariana Islands, for willfully violating anti-money laundering regulations. This penalty is a stark reminder of the importance of compliance with financial regulations and the severe consequences of non-compliance.
Violations by Tinian Dynasty
According to FinCEN’s assessment, Tinian Dynasty failed to file over 2,000 suspicious activity reports and currency transaction reports (CTRs) between January 2009 and April 2013. The casino also assisted undercover agents posing as customers in evading reporting requirements by accepting cash transactions without filing CTRs.
- Failed to file over 2,000 suspicious activity reports and CTRS
- Assisted undercover agents in evading reporting requirements
- Accepted large cash transactions without filing CTRs
Investigation Findings
The investigation revealed several other violations, including:
- The VIP Manager assisted an undercover agent in purchasing a $15,000 casino voucher with cash, and did not file a CTR.
- On multiple occasions, the casino accepted large cash transactions from the same undercover agents without filing CTRs.
- The Casino Manager provided detailed advice to undercover agents on how to conduct their transactions in a way that would avoid reporting requirements. The Manager referred to the threshold of $10,000 as the “magic number” that would trigger a CTR filing.
Failure to Implement Anti-Money Laundering Program
The assessment also revealed that Tinian Dynasty failed to implement an anti-money laundering program, resulting in its failure to file thousands of CTRs over a four-year period. This lack of a comprehensive program allowed the casino to operate without proper controls and safeguards to prevent money laundering.
Penalty Imposed by FinCEN
FinCEN Director Jennifer Shasky Calvery stated, “Tinian Dynasty’s blatant disregard for anti-money laundering regulations is unacceptable and undermines the efforts of law enforcement agencies to combat financial crimes.” The $75 million penalty imposed by FinCEN is the largest ever assessed against a casino operator for violations of Bank Secrecy Act (BSA) regulations.
Conclusion
The penalty imposed on Tinian Dynasty serves as a warning to all financial institutions and businesses operating in the financial sector: compliance with anti-money laundering regulations is essential, and non-compliance will be met with severe consequences.