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FinCEN Fines Tinian Dynasty Hotel & Casino $75 Mill on AML

Jaclyn Jaeger | June 5, 2015

The Financial Crimes Enforcement Network this week fined Hong Kong Entertainment (Overseas) Investments, doing business as Tinian Dynasty Hotel & Casino, $75 million for “willful and egregious” violations of the Bank Secrecy Act.

According to FinCEN, Tinian Dynasty failed to develop and implement policies and procedures designed to ensure anti-money laundering (AML) compliance, or to detect suspicious transactions. It also never conducted an independent test of its systems to ensure compliance. Further, casino personnel were not trained in BSA recordkeeping requirements or in identifying, monitoring, and reporting suspicious activity.

Tinian Dynasty accommodated patrons who desired to conduct financial transactions with large amounts of cash without the casino reporting the transactions. During a criminal investigation, undercover agents, posing as customers, told casino staff...

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