Record-breaking $75 million Penalty for Northern Mariana Islands Casino’s Money Laundering Lapses
Historic Fine Imposed by Financial Crimes Enforcement Network (FinCEN)
June 3, 2015 - The Financial Crimes Enforcement Network (FinCEN) slapped a record-breaking $75 million penalty on Tinian Dynasty Hotel & Casino in Saipan, Northern Mariana Islands, for chronic violations of the Bank Secrecy Act (BSA) regarding anti-money laundering (AML) procedures. This fine, the largest against a casino and the fourth-largest in FinCEN’s history, emphasizes the consequences of disregarding critical AML protocols.
Repeated Neglect of BSA Obligations
The casino, owned by Hong Kong Entertainment (Overseas) Investments, Ltd., consistently ignored its BSA responsibilities in the following manners:
- Failed to establish an effective AML program
- Neglected to conduct essential audits
- Ignored reporting or suspicion of transactions over regulatory thresholds
Disregard for Regulations Resulted in Severe Infractions
During an investigation, casino employees handed out more than $200,000 worth of casino chips to undercover agents without filing Currency Transaction Reports (CTRs) with FinCEN for transactions above the $10,000 threshold. Agents reportedly discovered approximately 2,000 unreported CTRs within the casino premises. Additionally, a VIP services manager allegedly informed a disguised representative of a Russian businessman that the casino would not report substantial transactions.
Criminal Prosecutions in Progress
Despite these extensive infractions, the U.S. Attorney’s Office in the Northern Mariana Islands is still pursuing criminal charges against Tinian Dynasty for 158 counts of AML violations taking place from September 2009 to April 2013. The jury trial is scheduled for June 30, 2015, and prosecutors claim the casino neglected to report an astounding $138 million in transactions.
Further Information
For complete coverage and additional information, please refer to FinCEN’s official press release and media articles from: