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Tinian Dynasty Hotel and Casino Hit With Record $75 Million Fine

Tinian Dynasty Hotel and CasinoCasinos are responsible for generating millions of dollars in revenue each year and are always under the watchful eye of the authorities because they are known to be used for money laundering, illegal wire transfers, drug smuggling and racketeering. The Tinian Dynasty Hotel and Casino located on Tinian, which is a part of the Northern Mariana Islands was part of a Treasury’s Financial Crimes Enforcement Network (FinCEN) investigation.

FinCen was investigating the Pacific Island casino for carrying out “willful and egregious violations” of the Bank Secrecy Act. In March 2015, FinCen imposed a record $10 million fine on the Trump Taj Mahal but the fine imposed on the Tinian Dynasty Hotel and Casino set a new record as the casino is now required to pay $75 million.

The investigation was thorough and revealed that the casino did not invest enough time nor money in maintain proper security procedures. The investigation revealed that the casino had not implemented a robust anti-money laundering program nor did it take the time to coach its casino employees on how to identify suspicious individuals and activity; the protocol of escalating such suspicious behavior or the procedure of maintaining accurate record keeping of all financial related transactions.

In a statement, FinCEN Director Jennifer Shasky Calvery said

Tinian Dynasty didn’t just fail to file a few reports. 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. Tinian Dynasty’s actions presented a real threat to the financial integrity of the region and the U.S. financial system.

FinCen had filed a detailed case that had 158 counts of criminal indictment and 156 charges accusing the casino of having no procedures in place to file and record currency transactions nor maintain a anti-money laundering system. The casino initially tried to get the judge to dismiss all charges but the judge dismissed the motion. Tinian Dynasty has never filed even one suspicious activity report but will now have to pay a heavy fine for not conforming to the Bank Secrecy Act.

Undercover officers entered the casino and approached staff with numerous requests that were not legal and were surprised to see the staff co-operating with them. FinCen hopes that this $75 million fine will discourage other casinos from violating any laws. The legal counsel for the casino, Bruce Berline stated that the casino had no comment at this point of time.