News & Analysis as of September 19, 2024

FinCEN › Casinos

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Nevada Gaming Control Board Alleges Casino AML Failures Based on Wagering of Customers Involved in Illegal Bookmaking

Ballard Spahr LLP on 8/27/2024

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

¿Cuándo Son Los Casinos Instituciones Financieras?

Foodman CPAs & Advisors on 1/10/2023

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

When Are Casinos Financial Institutions?

Foodman CPAs & Advisors on 11/23/2022

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

Mobile Sports Gambling and Sports Betting Risks

K2 Integrity on 1/27/2022

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

FinCEN provides regulatory relief to casinos, allowing “non-documentary” identification verification

Hogan Lovells on 10/21/2021

On October 19, 2021, FinCEN, the U.S. Government’s lead AML regulator, exercised its regulatory relief authority to allow casinos and card clubs to employ “non-documentary means” to verify patrons’ identity. The original...more

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

Ballard Spahr LLP on 2/28/2020

First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

AMA Updates AML Best Practices for AML Compliance

Ballard Spahr LLP on 12/31/2019

AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

FinCEN Director Emphasizes AML Priorities for Casinos, Sports Wagering, Mobile Gaming, and Card Clubs in Las Vegas Speech

Blank Rome LLP on 8/22/2019

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

FinCEN Director Blanco Addresses AML Compliance and Casinos

Ballard Spahr LLP on 8/15/2019

FinCEN Director Kenneth A. Blanco delivered prepared remarks on August 13 at the 12th Annual Las Vegas Anti-Money Laundering Conference. We previously have blogged repeatedly on the anti-money laundering (“AML”) and Bank...more

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

Dechert LLP on 5/22/2019

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

Once A “Patron,” Always A Patron?

Dickinson Wright on 8/14/2018

The Nevada Gaming Control Board (the “Board”) has been delegated the responsibility of resolving disputes between casino customers and the casinos pursuant to the process for patron disputes outlined in NGC Regulation 7A. ...more

The U.S. Casino and Gaming Industry: AML/BSA Regulation and Enforcement

Ballard Spahr LLP on 7/17/2018

As we blogged yesterday, British Columbia’s (“B.C.”) Attorney General David Eby recently released an independent and very detailed report examining money laundering in B.C.’s gaming industry and providing 48 recommendations...more

FinCEN Extends $3 Million Carrot to Card Club and Casino: Reduce Assessed Civil Penalty by Completing Compliance Undertakings

Ballard Spahr LLP on 5/7/2018

FinCEN announced on May 3, 2018 that Artichoke Joe’s, a card club and casino located in San Bruno, California and founded in 1916, has entered into a revised civil money penalty assessment regarding alleged deficiencies under...more

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

Bass, Berry & Sims PLC on 11/22/2017

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

California Card Club Plagued By Allegations Of Criminal Activity Fined $8 Million For AML Violations

Fox Rothschild LLP on 11/20/2017

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

2016 Year in Review: Money Laundering (Part One)

Ballard Spahr LLP on 2/3/2017

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

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

McGuireWoods LLP on 1/9/2017

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

Don’t Roll the Dice: FinCEN Assesses Significant Penalties on Regulated Entity for Failing to Implement a Comprehensive AML...

Bradley Arant Boult Cummings LLP on 10/28/2016

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

Upping the Ante on Casinos’ AML Compliance

K2 Integrity on 10/24/2016

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

FinCEN Assesses Significant Penalty Against Casino for Bank Secrecy Act Violations

Holland & Knight LLP on 7/19/2016

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

Repeat BSA Violations Cited for Two FinCEN Fines

Manatt, Phelps & Phillips, LLP on 4/25/2016

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

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

McGuireWoods LLP on 4/8/2016

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

FinCEN Imposes $650,000 Civil Penalty on Small ''Card Club'' Gaming Establishment

Ballard Spahr LLP on 1/7/2016

The Financial Crimes Enforcement Network (FinCEN) announced its first enforcement action against a small “card club” gaming establishment imposing a civil penalty of $650,000. The enforcement action, announced December 17,...more

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

Manatt, Phelps & Phillips, LLP on 9/22/2015

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

FinCEN Announces Caesars Penalty After Multiyear Investigation

McGuireWoods LLP on 9/14/2015

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

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FinCEN › Casinos

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