On June 3, 2015, FinCEN assessed a $75 million civil money penalty against a hotel and casino in the Northern Mariana Islands for violations of the BSA. The fine is the largest ever levied by FinCEN against a casino and the fourth largest ever imposed by the agency.

For years, Tinian Dynasty Hotel & Casino, owned by Hong Kong Entertainment (Overseas) Investments, Ltd., failed to establish and implement an effective anti-money laundering program or conduct audits of its compliance system as required by the BSA. It also failed to detect suspicious transfers or submit suspicious activity reports when transactions were conducted above the reporting threshold.

During an investigation of the casino, employees provided agents posing as gamblers with more than $200,000 in chips without filing Currency Transaction Reports (CTR), which are generally required to be filed with FinCEN for any exchange of currency of more than $10,000. During a subsequent search of the casino, law enforcement agents found more than 2,000 unfiled CTRs. A Tinian Dynasty VIP services manager also informed an agent posing as a representative of a Russian businessman that the casino would not file CTRs for large transactions.

A federal criminal case against Tinian Dynasty is pending in Northern Mariana Islands District Court for 158 counts of anti-money laundering violations from September 2009 to April 2013. Prosecutors alleged that Tinian Dynasty failed to report $138 million in currency transactions. The case is scheduled to go to trial on June 30, 2015.

For more details, please see FinCEN’s press release and news coverage from Compliance Week and The WSJ.