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FinCEN Fines First Card Club for Bank Secrecy Act Violations

Jaclyn Jaeger | December 23, 2015

The Financial Crimes Enforcement Network this week announced its first settlement with, and assessment against, a “card club” gaming establishment for violations of the Bank Secrecy Act (BSA). The settlement and FinCEN’s assessment requires Oaks Card Club to pay a fine of $650,000 for willful violations of the BSA.

Like casinos, card clubs are defined as financial institutions under the BSA and are subject to FinCEN’s rules. Among its failures, Oaks relied on an inaccurate and misleading anti-money laundering (AML) policy to train its staff. The AML policy failed to provide instructions, or provided wrong instructions, concerning the card club’s BSA obligations and filing of BSA reports, according to FinCEN.

For example, FinCEN said, Oaks encouraged employees to provide notice to patrons if they were about to conduct...

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