On June 3, FinCEN announced a $75 million civil money penalty against an international casino for alleged “willful and egregious” violations of the BSA. As detailed in the Assessment, the casino (i) failed to develop and implement an AML program; (ii) failed to designate an official BSA officer to oversee compliance requirements of the BSA; and (iii) failed to train employees in adequate recordkeeping, or in identifying, monitoring or reporting suspicious activity – all considered to be critical components of an adequate BSA/AML program. Moreover, FinCen alleges that casino employees “provided detailed instructions” to undercover agents on how to conduct transactions without being properly reported to U.S. authorities. FinCen’s latest action follows a March announcement, when the agency imposed a $10 million civil money penalty against a New Jersey-based casino.