U.S. government fines Tinian Dynasty $75 million

The U.S. government fined the Tinian Dynasty Hotel and Casino operator, Hong Kong Entertainment (Overseas) Investments, $75 million for “willful and egregious” violations of anti-money-laundering rules going back to 2008.

The fine, issued by the Treasury’s Financial Crimes Enforcement Network, was the biggest ever issued against a casino by the network and the fourth largest ever imposed on any entity by the agency, spokesman Steve Hudak told the Wall Street Journal.

In a statement FinCEN said Tinian Dynasty failed to develop and implement an anti-money laundering program. 

“No member of Tinian Dynasty staff was delegated responsibility for day-to-day compliance with the BSA. The casino failed to develop and implement policies and procedures designed to ensure AML compliance, or to detect suspicious transactions; it also never conducted an independent test of its systems to ensure compliance…,” FinCEN said in a statement.

The statement added that casino personnel were not trained in BSA recordkeeping requirements or in identifying, monitoring, and reporting suspicious activity. The casino, in fact, said it could facilitate large amounts of currency and not file reports relating to these transactions on an occasion when an undercover agent posed as a representative of a Russian businessman, FinCEN said.

“Tinian Dynasty didn’t just fail to file a few reports,” said FinCEN Director Jennifer Shasky Calvery. 

“The casino operated for years without an AML program in place. It failed to file thousands of CTRs and its management willfully facilitated suspicious transactions and even provided helpful hints for skirting and avoiding the laws in the U.S. and overseas.”

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