FinCEN's $8 million civil money penalty imposed on Caesars Palace for "willful and repeated" violations of the BSA sends a signal that failure to collect and use appropriately identifying information from customers, and other AML compliance program shortcomings, will not be tolerated. Caesars Palace, which is in bankruptcy, suffered from "systemic and severe AML compliance deficiencies," allowing a "blind spot" to exist in its compliance, the regulator said, adding that the casino turned a blind eye to its private gaming salons, where patrons were openly allowed to gamble anonymously.

"Despite the elevated money laundering risks present in these salons, Caesars failed to impose appropriate AML scrutiny, which allowed some of the most lucrative and riskiest financial transactions to go unreported," FinCEN said. The failure to adequately monitor transactions—including large wire transfers—compromised the casino and exposed the U.S. financial system to illicit activity, the regulator alleged.

In addition to the $8 million civil money penalty, Caesars agreed to conduct periodic external audits and independent testing of its AML compliance program. The casino will report to FinCEN on the improvements required by the deal, adopt a "rigorous" training program and engage in a retroactive review of suspicious transactions.

To read the NPRM, click here.

To read the assessment in In re Desert Palace Inc., click here.