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Thank you, for the kind introduction. I would also like to thank Casino Essentials for hosting this Title 31 conference and inviting me to speak today. I am honored to be here talking with you about the importance of compliance with anti-money laundering AML requirements under title 31 of the Bank Secrecy Act. You all—as industry leaders and compliance officers—play a significant role in the fight against illicit finance. Events like this serve a vital role in promoting constructive and open dialogue between industry, regulators, and law enforcement.
That kind of dialogue truly benefits all of us. The reporting requirements the BSA imposes on financial institutions—including casinos—provide an invaluable source of information for law enforcement in our efforts to deter, detect, and prosecute criminal actors.
It is no secret that criminal actors seek to use the tools of our financial and banking systems to serve their illicit purposes: For an illegal enterprise to succeed, criminals must be able to hide, move, and get access to their criminal proceeds.
And when they do, their actions serve as a dual threat: It is for these reasons—the need to detect and deter criminal conduct AND to preserve the integrity of the financial systems they seek to exploit—that there are serious consequences for financial institutions that fail to satisfy their BSA obligations. Thus both law enforcement and industry have a shared interest in ensuring effective BSA compliance. I will also discuss some specific measures that the gaming industry can take to ensure that casinos and card clubs do not become conduits for criminals seeking to launder their illicit funds.
First, some background on my section of the DOJ: We do this, first and foremost, by prosecuting and coordinating complex, multi-district and even international money laundering and asset forfeiture investigations and cases. In addition, we provide legal and policy assistance regarding anti-money laundering and asset forfeiture to federal, state, and local prosecutors and law enforcement, and also to foreign governments.
It bears noting outset that in my experience—when it comes to BSA compliance—most financial institutions are committed to fulfilling their obligations under the BSA and to ensuring that they avoid doing business with criminal actors. As compliance officers, you no doubt recognize your duty to ensure compliance by your institutions and prevent regulatory violations. The vast majority of financial institutions—and compliance officers—that take these duties seriously are, as I have noted, vital to our efforts to detect, investigate, and prosecute Game Of Chance Casino Essentials Title criminal actors who seek to exploit our financial system.
In cases where we find repeated willful violations of clear legal obligations, the Department of Justice and AFMLS will step in to criminally pursue these bad actors— both the individuals and, where appropriate, the financial institutions themselves. As I noted at the outset, financial institutions, including casinos and card clubs, are vital to our law enforcement efforts.
For this reason, compliance officers like many of you here today are critical to protecting the reputations of your institutions by preventing where possible or detecting and reporting criminal activity by customers seeking to exploit your services. It is not an exaggeration to say that compliance is fundamental to protecting the security of our financial institutions and is essential to the integrity of our entire financial system. Despite its importance, compliance often takes a back seat to other financial considerations.
That view can be especially true in the gaming industry where financial services—and their attendant compliance costs—may be considered secondary to or even inconsistent with the primary mission of customer entertainment. In stark contrast to the outward glamour of Las Vegas casinos, compliance can be tedious, painstaking, and thankless.
We at the Department of Justice understand this reality. And we appreciate that, despite these challenges, you and your colleagues are committed to helping protect the integrity of your institutions and assisting law enforcement.
The requirement for casinos and other financial institutions to have effective anti-money laundering programs has been on the statute books only sincewhen Congress passed the Patriot Act, which included amendments that required casinos and other institutions to implement effective AML programs. I want to emphasize something here. They are necessary for the establishment and maintenance of an effective AML program, but they may not be sufficient given the specific risks confronting a particular institution.
These are just some of the Game Of Chance Casino Vendors Directory of a strong compliance program. Put differently, we look at whether an institution meaningfully stressed compliance or, when faced with a conflict between compliance and profits, chose profits.
It is important to remember that anti-money laundering and BSA compliance is not an end itself but is a means to Game Of Chance Casino Essentials Title end: Too often, BSA compliance is regarded as a mere box-checking exercise, with more emphasis on process than results. But it is one thing to have the requisite tools in place; it is another to deploy those tools most effectively.
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With that in mind I would like to discuss what steps in particular the gaming industry should be taking to detect and deter illicit financial activity. Of course, it may be difficult for a casino or card club to truly know all of its customers that pass through its gaming floors.
However, under a risk-based approach to compliance, steps should be taken to identify those customers, by gaming activity or personal background, who pose the greatest risk to your business. This is why it is critical for the gaming industry to use all available information to identify its customers for BSA purposes.
This may mean that a casino should be using its business side to assist the compliance side of the house. For example, do the compliance officers have the ability to access and use information contained in business resources like customer club account cards or markers to assist in identifying a customer? Hawaiian Gardens routinely collected customer information through its player club card accounts.
Despite having this significant trove of information regarding its customers, Hawaiian Gardens failed to utilize that information for suspicious activity reporting purposes. I cannot emphasize this point enough: Casinos and card clubs should also make an effort to identify the beneficial owners of funds when it is apparent that transactions are being conducted by or through a third party.
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These types of arrangements create an enticing method for criminals to move illicit funds to or through casinos or card clubs and their use should raise a red flag for compliance officers: You need to know the beneficial owners of those funds. A casino or card club may need to look at other factors, such as whether the customer is from a high-risk jurisdiction with poor AML controls, or is a politically exposed person from a country with significant public corruption.
These are all indicators that will help a casino or card club in truly knowing its customers and ensuring proper BSA compliance. Despite the elevated risks present in these salons, Caesars failed to apply appropriate AML scrutiny, thus allowing some of the riskiest financial transactions to go unreported. Furthermore, Caesars marketed these salons through branch offices in the U. Caesars made the effort to identify and entice these customers to travel across the world to come gamble at their institution, but, when it came time to compliance with its legal BSA requirements, Caesars looked in the other direction.
Therefore, we urge you, as leaders of the gaming industry, to take prudent steps to know who you customers are, even and perhaps especially those who may be the beneficial owners of legal entities.
For example, if one branch identifies potentially suspicious activity related to a customer, compliance personnel at other branches should be alerted to this activity. Along those same lines, U. This is especially important for transfers between a U.
Simply because funds are moved between affiliated casino accounts does not excuse the U. This may sound straightforward in principle, but we have seen that it is all too often not implemented in practice. Let me pause here to emphasize this point. By partnering with regulators and law enforcement, your institutions will be better positioned to detect and address illicit activity.
This requires institutions to play a more proactive role that goes beyond simply filing SARs and cooperating with grand jury subpoenas. Take advantage of the opportunity at this conference to get to know some of the law enforcement representatives who work on these issues. Then, if in your work you identify significant suspicious activity, you have a name and a phone number that you can call in law enforcement in addition to filing a SAR.
By consulting with law enforcement upon Game Of Chance Casino Essentials Title of suspicious activity, an institution may be able to avoid taking actions that unintentionally harm a criminal investigation or benefit the criminal. For example, when an institution unilaterally terminates a relationship with a suspicious customer, that termination might prompt the criminal to move and hide his illicit funds elsewhere. But, if you reach out to Game Of Chance Casino Essentials Title enforcement proactively, there are a number of steps we might wish to take depending on the nature of what you have identified.
Maybe we will ask you to leave the casino account open so we can monitor the activity. Maybe we will seek a restraining order or a seizure warrant from a judge to give us time to gather more evidence.
While FinCEN has been very active on this front in the last two years, make no mistake, the DOJ will pursue criminal charges and penalties against any financial institution—including casinos and card clubs—that willfully violates the BSA. We expect you, as members of the financial community, to take compliance risk at least as seriously as you take other business-related risks.
The Department is keenly aware of the unique compliance challenges faced by casinos and card clubs. You represent an industry that is primarily focused on providing entertainment to its customer base, with financial services being a complementary element of Real Money Casino Games For Android Tablet business model.
Nevertheless, because you do offer those financial services to your customers, you have taken on a great responsibility in the fight against illicit finance. And that responsibility is growing: As a result, I strongly encourage each of you to take the opportunity— both today and once you return to your respective offices—to reflect on whether your institutions have effective AML programs and other compliance policies and practices to prevent or mitigate financial crime.
All of us here today share the goal of ensuring a financial system free from illicit proceeds and criminal abuse. I am grateful for the opportunity to speak with you today, and am confident that this forum will prompt meaningful discussion regarding these important issues.
That concludes my prepared remarks.
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I would like to thank Mindy for the very kind introduction, as well as Jim Dowling, who invited me to speak today. I want to also thank every one of you who are on the front lines of BSA compliance. Casinos and card clubs play a critical role in keeping our financial system safe from potential money laundering and terrorist finance.
The high level of attendance at this conference and the questions you have raised tells me that the casino industry continues to show a strong interest in developing a deeper understanding about these issues. And, I am very happy to be a part of the discussion. Let me next provide a brief overview of FinCEN, for those of you who might not be as familiar with our role.
As you are aware, FinCEN has had some recent changes in its senior management with the departure my predecessor, Stephanie Brooker, in April of this year, followed by our director, Jennifer Shasky Calvery, at the end of May. And, I can assure you that we are continuing our work while we await the announcement of a new director. I can also assure you, that for at least the Enforcement Division, we will continue to follow the same trajectory with respect to our priorities and practices.
With approximately employees, we are relatively small considering our broad responsibilities. Our mission is to safeguard the financial system from illicit use and combat money laundering and promote national security Game Of Chance Casino Essentials Title the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities. Some of the threats we are focusing on at FinCEN include Mexican drug trafficking organizations, transnational criminal organizations, frauds against U.
These are serious threats to the United States, our people, our businesses, and our communities. The BSA Nya Casino Bonusar FinCEN with broad supervisory and enforcement authority, allowing FinCEN to impose civil penalties not only against domestic financial institutions, but also against partners, directors, officers, and employees of such entities who themselves participate in misconduct.
We do consider potential individual liability. We also have the authority to obtain injunctions against institutions, as well as individuals, that we believe are involved in violations of the BSA. In our BSA oversight role, we, of course, focus on compliance in all our regulated industry sectors. Since joining FinCEN a little over two years ago, I have gained a deeper understanding of the relevant perspectives and equities that exist across diverse financial sectors.
FinCEN is in a novel position as a regulator. It must vigorously enforce the rules that financial institutions such as casinos and card clubs are required to follow to guard against money laundering, terrorist finance, and other financial crime.
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A blackjack game has a dealer and one or more players. When discussing casino games, one usually nds statements such as the ones above saying something The professionals in the casino community know this. Several years ago while I was in Athens to speak at a conference, I had.
It is imperative that policies and procedures are in place to assist with knowing your customer and meeting your reporting and recordkeeping requirements. The assessment against this card club also stressed the importance of how customers who engage in suspicious activity should be handled by a casino. It highlighted an unknown customer on whom there were 15 SARs filed, and who refused to provide identification on multiple occasions.
Nevertheless, this customer was allowed to continue to gamble there without any additional due diligence or further action taken by the card club—despite an independent test that made this very recommendation.
This card club put profits before compliance—but it ultimately cost them. Further, this action also demonstrated the importance of filing quality SARs. The card club in this case would file numerous SARs on customers, but none of these SARs indicated or reflected the fact that the customers in question were prior subjects of SARs or identified patterns of suspicious activity.
This requirement plays a critical role in providing law enforcement with the information they need—which the BSA expressly states as one of the underlying purposes of the SAR provisions. Finally, the action we took in this case continued our practice of establishing a remedial framework to help rectify the deficiencies highlighted in our assessment. BSA reports filed by our financial institutions, including casinos and card clubs, provide some of the most important information available to law enforcement and other agencies safeguarding the United States.
While, as I have said, there are notable advancements in SAR filings by the gaming industry, there are still challenges we are working to overcome. I can understand the origin of this myth. Everyone wants to know and be sure that their SAR filings are serving their purpose; assisting law enforcement investigations and stopping illicit behavior.
There are certainly important reasons for some of the silence on this: SAR confidentiality, law enforcement sensitivities, intelligence concerns, among other reasons all can make it difficult to give feedback on specific filings by financial institutions. However, it bears repeating what both our former Director and my immediate predecessor have stated at conferences in the past: Not every SAR results in a criminal prosecution.
Now, in my role at FinCEN, I see how important our partner regulators and stakeholders also view this data. Taken together, BSA data includes nearly million records and there are around 55, added each day. The reporting contributes critical information that is routinely analyzed, resulting in the identification of suspected criminal and terrorist finance activity and the initiation of investigations.
Domestically, FinCEN grants more than 10, agents, analysts, and investigative personnel from over unique federal, state, and local agencies across the United States with direct access to the reporting. There are approximately 30, searches of the BSA data taking place each day. In addition, more than SAR review teams and financial crimes task forces across the country bring together prosecutors and investigators from different agencies to review BSA reporting related to their geographic area of responsibility and insatiate investigations.
Every day, we see the BSA data being used by our law enforcement partners. For specific examples of the significant role casino SARs play in law enforcement investigations, I would invite you to look at our recent Law Enforcement Awards Ceremony. This ceremony took place in May at the Treasury Department headquarters next to the White House, and a representative of the American Gaming Association participated.
BSA reports from multiple financial institution—including casinos—identified the perpetrator of the scheme, and noted an increase in cash transactions in his personal accounts. Investigators used the information provided by the reporting financial institutions to uncover the full magnitude of the scheme and to successfully prosecute the perpetrator.
Ultimately, the perpetrator pled guilty to federal charges of money laundering, and wire and mail fraud, and was sentenced to several years of imprisonment and ordered to pay hundreds of thousands of dollars in restitution. Other examples of where BSA filings contributed to a successful U. Internationally, FinCEN also facilitates the sharing of information for criminal and terrorism investigations on both a bilateral and multilateral basis through the Egmont Group of Financial Intelligence Units.
The Egmont Group, currently comprised of over member jurisdictions, provides an unparalleled, preexisting platform for the secure exchange of financial intelligence. In response to some recent world events, FinCEN has been called upon to provide any relevant BSA data it has received from financial institutions. This is a common myth across all financial sectors. And, I think this myth may stem from not fully appreciating or understanding how valuable a complete and accurately filed SAR can be in an investigation.
What does this mean for your SAR filed on a low-dollar amount transaction? Well, regardless of the amount, the reporting aids in expanding the scope of ongoing investigations by pointing to the identities of previously unknown subjects, exposing accounts and hidden financial relationships, or revealing other information such as common addresses or phone numbers that connect seemingly unrelated participants in a criminal or terrorist organization and, in some cases, even confirming the location of suspects.
The reporting—even of transactions involving low dollar amounts—has served to unmask relationships between illicit actors and their financing networks, enabling law enforcement to target the underlying conduct of concern, and to disrupt their ability to operate. Your filing may just be the source of a missing piece of information that is needed in an investigation. Law enforcement also uses the reporting to identify significant relationships, patterns, and trends.
Your filings contribute to a more comprehensive picture that informs our understanding and analysis of criminal typologies. FinCEN includes an Intelligence Division that uses SARs and other reports to conduct strategic analysis to identify new trends and emerging threats in illicit finance. It assesses AML compliance across industries, identifying new illicit finance trends and developing typologies for illicit activity.
We hear this one a lot. But this requirement goes beyond a speech given by FinCEN—the regulations themselves support this statement. Casinos and card clubs are required to develop and maintain a robust risk-based AML program. It is a voluntary program that can assist in helping casinos and card clubs obtain missing information to meet their regulatory obligations.
Section b provides a safe harbor that offers protections from liability. When a financial institution notifies FinCEN of its intention to participate in this information sharing program, FinCEN first validates the registration. Once approved, the financial institution is provided access to the most current list of b participants, which is used by the financial institution to validate that they are sharing with a legitimate participant.
Additional information about the b program can be found on the FinCEN web site. But if that were true, then there is no way a financial institution can ever violate the statute—the defense would just be: Obviously, an effective AML system cannot work like that. Similarly, some financial institutions hold on to the myth that their AML program should be based on their risk appetite or risk tolerance. This view may be compounded by the misperception that SAR filings can be proportionally based on the size of an AML program.
These related myths are also contradicted by the rule [31 CFR So if you have a reason to suspect it, then you are required to file. It is that simple. Decisions are not always clear-cut. However, I must emphasize financial institutions like yours and those of your clients must have appropriate risk-based AML programs in place.
That concludes my attempt to dispel four common myths about SAR filing. I can step off my soap-box for a moment. Because—the good news is that the casino and card club industry has improved their filing of SARs over the past several years. I want to thank the BSA compliance officers here today for being part of this positive change. Generally, I do not like to throw out a lot statistics. SAR filings in the first reportable months of also appear to continue this upward trend.
Notably, these increases have occurred industry-wide. We have observed increases in state-licensed casinos, tribal casinos, and card clubs. Based on data you provided us, the highest reported categories of suspicious activity by your industry in are—again, as they were in —minimal gaming and altering transactions to avoid CTR filing, whether by structuring or other means. In the final portion of my presentation, I want to now provide additional clarity about how FinCEN assesses the amount of civil monetary penalties CMPs.
I hope to provide some greater insight to our CMP process to better inform you and your colleagues. FinCEN does not maintain a strict matrix for assessing penalties. I believe that overall, this model promotes greater fairness and proportionality in our enforcement actions. And, it works to provide parity with CMPs imposed in similar cases. As I mentioned earlier, we devote a tremendous amount of time to ensuring that our public enforcement assessments clearly explain the nature of the violations underlying our enforcement action.
The rationale should, in most instances, be evident. This is fairly obvious. FinCEN will consider the nature and seriousness of the violations in assessing an appropriate penalty or other relief. This factor involves both a qualitative and a quantitative analysis. For example, what elements of a BSA program are deficient or missing? A financial institution that has significant deficiencies in multiple program pillars over an extended period of time may be in a different position than an institution that has failed to comply with a single program area for a short period of time.
Of course, willfulness is an element in all BSA cases. Financial institutions or individuals that cause AML deficiencies by recklessly failing to comply with their obligations under the BSA, or turn a blind eye to compliance deficiencies will be considered to have acted willfully for the resulting violations.
In some instances, we have seen cases where an employee or officer of the institution has been complicit in illicit transactions, or the institution has had direct notice of ongoing money laundering or BSA violations but allowed it to continue. For example, prior exam findings, or receipt of a grand jury subpoena.
Cases in which the IRS examiners have found repeat violations over multiple exams receive heightened scrutiny from FinCEN and tend to be subject to greater penalties. However, this does not mean that a clean exam, or one with few findings, will never result in a CMP. We are also aware of disturbing instances in which our IRS examiners were denied access to critical information and key personnel during the exam process.
Obviously, obstructing the examination process and failing to address repeated violations are heavily weighted factors that we consider in enforcement actions and penalty determinations.
In such a case—or where the deficiencies or illegal activities are only discovered through examination or law enforcement investigation—it is likely a higher CMP will be imposed. FinCEN may consider the degree to which a financial institution or individual has cooperated with FinCEN, examiners, or law enforcement. A strong level of cooperation may be a mitigating factor in determining a penalty.
For example, we may insist on corporate monitor arrangements as part of our enforcement settlements. Our enforcement undertakings may require a casino to have more stringent independent testing for a given period of time, demonstrated training improvements, or updates to their written policies and procedures.
These undertakings serve as a way to remedy any potential violations and ensure that future issues do not arise.
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