On April 5, FinCEN assessed a civil money penalty against a Nevada-based casino for willfully violating the anti-money laundering provisions of the BSA. From 2010 through November 2013, the casino allegedly failed to (i) establish and implement an effective, written anti-money laundering program; (ii) establish and maintain appropriate internal controls in compliance with the BSA’s reporting requirements; (iii) conduct independent testing of its AML program; (iv) implement automated data processing systems that ensured compliance with the BSA and the casino’s AML program; (v) report suspicious activity; and (vi) secure and retain certain required records. According to FinCEN, the casino generally “lacked a culture of compliance” and had a “blatant disregard for AML compliance permeat[ing] at all levels.” The casino agreed to a $1 million civil money penalty and admitted to willfully violating the BSA’s program, reporting, and recordkeeping requirements.