Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Tag Archives: Bank Secrecy Act

Anti-Money Laundering, Enforcement and Prosecution Policy and Trends, Securities and Commodities

SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer

As we have highlighted in prior posts, regulators of financial institutions, including FinCEN, FINRA and SEC, have increasingly brought actions to bring organizations – and individuals – into compliance with AML / BSA obligations.  This enforcement activity is consistent with FinCEN’s August 2014 Advisory, now nearly three years old, emphasizing the idea that U.S. financial institutions… Continue Reading
Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

FinCEN Announces Caesars Penalty After Multiyear Investigation

This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in SEC filings in late 2013. The investigation grew out of a 2012 audit performed by FinCEN’s examiner, the Internal Revenue Service Small Business/Self-Employed… Continue Reading
Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

Casino Forfeiture a Reminder that FinCEN’s Regulatory Oversight May Involve DOJ and Criminal Penalty

In early June 2015, FinCEN assessed a civil money penalty on the Tinian Dynasty Hotel & Casino, located in the Northern Mariana Islands, an archipelago to the east of the Philippines (don’t feel bad if you click here to learn a little more). Being a U.S. territory, the Northern Marianas are subject to federal regulation.… Continue Reading
Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

FinCEN Reasserts its Commitment to Casino Oversight and Enforcement

In a recent post we described a number of steps taken over the last year by the primary federal regulator for casinos – the Financial Crimes Enforcement Network (FinCEN) – that should cause casino operators to have Title 31 and Bank Secrecy Act (BSA) compliance among their top priorities. Based on this FinCEN activity, the… Continue Reading

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