Submission Type

Presentation

Session Title

Session 3-1-C: Past, Present, and Future Issues in Gambling Policy

Location

Caesars Palace, Las Vegas, Nevada

Start Date

30-5-2019 9:00 AM

End Date

30-5-2019 10:25 AM

Disciplines

Business Law, Public Responsibility, and Ethics

Abstract

This section will discuss eight important FinCEN enforcement actions that occurred from 2015 through November 2017, against five casinos and three card clubs for violating BSA casino civil regulatory requirements, and in some instances federal anti-money laundering laws. Also, this section will discuss two criminal cases against a casino and a card club that occurred in 2015 and 2016. This discussion is a summary of those actions intended to provide gaming regulators, United States Attorneys, special agents, and IRS civil examiners with an understanding of these BSA and AML regulatory actions to alert them to the challenges and problems the casino and card club industries face, as well as the lack of compliance programs reasonably designed to combat money laundering and terrorist financing.

Keywords

Bank Secrecy Act, Anti-Money Laundering, Casino Enforcement Actions

Author Bio

Leonard C. Senia, B.A. & M.P.A., during his 21-year career with Treasury Department/Financial Crimes Enforcement Network (FinCEN) wrote: (a) 4 proposed and 5 final Federal anti-money laundering regulations, (b) 12 casino guidance and advisory documents (88 pages), & (c) 3 administrative rulings pertaining to specific requirements for the casino & card club industries. Also, he was FinCEN’s resident casino expert who provided numerous customized training classes & case support work, upon request, to Federal & State prosecutors, investigators, & examiners pertaining to: (a) Bank Secrecy Act casino regulatory requirements, (b) how casinos and card clubs are organized and operate, (c) casino computerized and manual recordkeeping and reporting systems, (d) casinos and card clubs vulnerabilities to money laundering, & (e) Internet gambling. He worked closely with IRS on civil investigations into the casino gambling industry to evaluate its compliance with anti-money laundering rules regarding currency transaction and suspicious activity reporting. He was part of 3-person teams that civilly prosecuted 22 casinos for violations of Treasury's anti-money laundering regulations, which all ended in civil monetary penalties being paid. Organizer, coordinator, and a principal speaker for 5 FinCEN domestic and international anti-money laundering conferences involving casino matters held for 1 to 2 ½ days. Also, organizer, coordinator, and principal speaker for eight 1-day BSA anti-money laundering training conferences for the Nevada casino industry. His duties included assisting Organized Crime Drug Enforcement Task Force investigations in reviewing casino records & preparing special agents to testify in criminal casino cases. In September 2013, the Secretary of the Treasury recognized Mr. Senia with the “Albert Gallatin Award” commendation for 20 years of esteemed contributions to the public service. In 2006, the Director of the Federal Bureau of Investigations recognized Mr. Senia for “Exceptional Service in the Public Interest.”

Since September 2013, he has been a Consultant, Speaker, Trainer & Author in areas of anti-money laundering (AML)/financial crimes, risk assessments, computerized casino & card club reporting systems, operation of cage & credit systems, player tracking systems, Internet gambling systems & Macau VIP room/casino operator programs. He has provided consulting services to money services business redeeming Bitcoin, U.S. mega-casino corp., offshore casino, 2 California card clubs, international casino consultancy & several attorneys with bankruptcy cases against casino operators. He provided casino training ranging from 1/2 day to 2 days to the FBI, 3 State gaming regulatory agencies, a State law enforcement agency, CPA firm & U.S. provider of financial services technology. Also, he provided one-half day of BSA/OFAC training at 2 casino seminars. Lastly, he spoke at 6 domestic & 3 intl. casino conferences & 6 times was a guest lecturer in business law at State Univ. of NY College at Buffalo. Member Assn. of Certified Anti-Money Laundering Specialists (ACAMS). He has published 6 scholarly AML/OFAC articles & an AML chapter and a casino operations chapter in a casino regulators book, totaling 266-pages.

Funding Sources

No funding sources

Competing Interests

No financial or non-financial competing interests over last 3 years.

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May 30th, 9:00 AM May 30th, 10:25 AM

Recent Casino and Card Club BSA and AML Enforcement Actions

Caesars Palace, Las Vegas, Nevada

This section will discuss eight important FinCEN enforcement actions that occurred from 2015 through November 2017, against five casinos and three card clubs for violating BSA casino civil regulatory requirements, and in some instances federal anti-money laundering laws. Also, this section will discuss two criminal cases against a casino and a card club that occurred in 2015 and 2016. This discussion is a summary of those actions intended to provide gaming regulators, United States Attorneys, special agents, and IRS civil examiners with an understanding of these BSA and AML regulatory actions to alert them to the challenges and problems the casino and card club industries face, as well as the lack of compliance programs reasonably designed to combat money laundering and terrorist financing.