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Bank Secrecy Act › 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 -
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

Jenner & Block

Client Alert: Illuminating the Bank Secrecy Act: Key Takeaways from Recent DOJ Settlements

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The Department of Justice recently announced settlements with two casinos to resolve an investigation into alleged money laundering and violations of the Bank Secrecy Act (BSA). The settlements required the casinos to pay a...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Casinos

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...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

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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

Cozen O'Connor

Mobile Banking App Banned | Sticky Life Alert Contracts | Casino Pays Price For Misleading Regulators

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2023 AG Elections- Candidates Ready to Vie for Louisiana Attorney General’s Office Should Incumbent Not Seek Reelection •Louisiana Third District Attorney John Belton announced his plans to run for Louisiana AG if...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

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Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...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

Dechert LLP

Financial Crimes Enforcement Network, Treasury Department Affirm Regulatory Regime for Convertible Virtual Currencies

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more

Foodman CPAs & Advisors

Did you know that Casinos are Financial Institutions?

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Since 1985, Casinos that have Gross Annual Gaming Revenues in excess of $1,000,000 are considered to be Financial Institutions and are subject to the requirements of the Bank Secrecy Act (BSA). ...more

Bass, Berry & Sims PLC

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

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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...

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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

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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

Manatt, Phelps & Phillips, LLP

Repeat BSA Violations Cited for Two FinCEN Fines

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Repeat violations of the Bank Secrecy Act (BSA) are cited by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) for a $1 million penalty against a casino and a $10,000 fine against a money...more

McGuireWoods LLP

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

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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

Manatt, Phelps & Phillips, LLP

FinCEN Action Against Casino for Weak AML Compliance Efforts Should Not Be Ignored by Others—Especially Digital Currency Companies

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Why it matters - FinCEN's $8 million civil money penalty imposed on Caesars Palace for "willful and repeated" violations of the BSA sends a signal that failure to collect and use appropriately identifying information...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

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