Panel Title

Session 1-2-A: Why We Want (and Don’t Want) Gaming

Location

The Mirage Hotel & Casino, Las Vegas, Nevada

Start Date

7-6-2016 10:30 AM

End Date

7-6-2016 12:00 PM

Abstract

Historically, the U.S. government has not shown much interest in Bank Secrecy Act or Anti-Money Laundering enforcement compliance in the gaming industry. Instead, the focus tended to be on the banking industry. Perhaps, the gaming industry's unique culture and business model as compared to other financial institutions helped keep the industry off the government's Bank Secrecy Act enforcement radar. Whatever the reason, that all changed a few years ago.

In the past few years FinCEN and U.S. prosecutors have been enforcing the BSA aggressively in the gaming industry. Cumulatively, a handful of U.S. casinos have accounted for over nearly $150,000,000 in the return of funds to the government or civil fines. Understanding what happened in these cases is critical to not only understanding the government's enforcement focus, but to hopefully avoiding your casino from repeating the same mistakes.

Repeating these mistakes, particularly now that the industry is on notice of the government's enforcement agenda, could be very costly in a variety of ways. This session will examine several major recent enforcement actions and provide guidance on how your property can avoid the same mistakes.

Keywords

Bank Secrecy Act; anti-money laundering; FinCEN; compliance

Disciplines

Gaming Law

Comments

Audio recording of this presentation is attached as a downloadable MP3 audio file, 58.8 MB

This presentation begins at 30:47.

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Jun 7th, 10:30 AM Jun 7th, 12:00 PM

Those Who Don’t Know History Are Doomed To Repeat it: Understanding Government’s Recent Gaming Enforcement Actions

The Mirage Hotel & Casino, Las Vegas, Nevada

Historically, the U.S. government has not shown much interest in Bank Secrecy Act or Anti-Money Laundering enforcement compliance in the gaming industry. Instead, the focus tended to be on the banking industry. Perhaps, the gaming industry's unique culture and business model as compared to other financial institutions helped keep the industry off the government's Bank Secrecy Act enforcement radar. Whatever the reason, that all changed a few years ago.

In the past few years FinCEN and U.S. prosecutors have been enforcing the BSA aggressively in the gaming industry. Cumulatively, a handful of U.S. casinos have accounted for over nearly $150,000,000 in the return of funds to the government or civil fines. Understanding what happened in these cases is critical to not only understanding the government's enforcement focus, but to hopefully avoiding your casino from repeating the same mistakes.

Repeating these mistakes, particularly now that the industry is on notice of the government's enforcement agenda, could be very costly in a variety of ways. This session will examine several major recent enforcement actions and provide guidance on how your property can avoid the same mistakes.