Submission Title
Session Title
Session 1-2-A: Why We Want (and Don’t Want) Gaming
Presentation Type
Event
Location
The Mirage Hotel & Casino, Las Vegas, Nevada
Start Date
7-6-2016 10:30 AM
End Date
7-6-2016 12:00 PM
Disciplines
Gaming Law
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
Streaming Media
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.
Comments
Audio recording of this presentation is attached as a downloadable MP3 audio file, 58.8 MB
This presentation begins at 30:47.