Friday, June 26, 2015

FinCEN Enforcement Stacks the Deck in AML Compliance for Casinos and Card Clubs

June 25, 2015 - Introduction Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”), recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the conference were the State Bar of Nevada’s Gaming Law Section, the American Gaming Association, and the University of Nevada–Las Vegas’ International Gaming Institute.

FinCEN is one of the Treasury Department’s primary agencies to oversee and implement policies to prevent and detect money laundering, and the only federal agency to oversee anti-money laundering (“AML”) compliance by casinos and card clubs. FinCEN polices for compliance with AML laws, including the Banking Secrecy Act (“BSA”), which requires certain reporting and recordkeeping by casinos and card clubs in an effort to prevent various financial and crimes. FinCEN works closely with the Internal Revenue Service (“IRS”) Small Business/Self-Employed Division, which is FinCEN’s delegated examiner for casinos and card clubs. The IRS refers significant violations of AML laws to FinCEN for enforcement action. FinCEN also receives referrals and coordinates its enforcement investigations with criminal law enforcement agencies, including the IRS-Criminal Investigations, the FBI, the Department of Justice’s Asset Forfeiture and Money Laundering Section, and U.S. Attorney’s Offices and state authorities, as well as other regulatory partners, including the Nevada Gaming Control Board.

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Saturday, June 20, 2015

Casinos are improving their efforts to fight money laundering, Treasury official says

By: J.D. Morris, Vegas Inc

The gaming industry’s fight against criminals who want to use casinos to disguise illegal money was front and center Thursday at the Paris resort.

There, industry leaders and government officials gathered for a conference that addressed how casinos are handling their obligations under anti-money-laundering law.

The verdict, according to one government official: Casinos have done a better job lately of reporting suspicious financial activity, but there’s still room for improvement.

Last year, the director of the Treasury Department’s Financial Crimes Enforcement Network — or FinCEN — spoke at this same Bank Secrecy Act conference and reminded the casino industry of how it needs to instill itself with a “culture of compliance” when it comes to money-laundering law.

The casino industry is listening, apparently.

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Thursday, June 18, 2015

Familiar names appear in money laundering report

It’s called the National Money Laundering Risk Assessment, and it’s one of those yearbooks the image-conscious folks at Gaming Inc. would rather not find their names in.

Each year the U.S. Department of Treasury issues its money laundering status report along with its National Terrorist Financing Risk Assessment in a one-two punch that helps bring the risk that illicit money changing poses to the U.S. financial system and national security into a sharper focus.

It’s neither a scandal nor a surprise that the Money Laundering Risk Assessment devotes part of its review to the casino industry as part of a section titled “Vulnerabilities and Risks: Money Laundering Methods.” With more than 1,300 casinos and card rooms in 42 states, according to the American Gaming Association, and 246 Native American tribes generating $27 billion in revenue in 2012, the stakes are high. Not surprisingly, Nevada and New Jersey casinos generated more than 40 percent of the 27,000 Suspicious Activity Reports filed in 2013.

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Monday, June 15, 2015

Treasury Department Publishes National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment

Reports Identify Key Illicit Finance Concerns to the United States; Enable the Public and Private Sectors to More Effectively Manage and Combat Illicit Finance Risks

June 12, 2015 - WASHINGTON - The U.S. Department of the Treasury today issued the National Money Laundering Risk Assessment (NMLRA) and the National Terrorist Financing Risk Assessment (NTFRA). The purpose of these assessments is to help the public and private sectors understand the money laundering and terrorist financing methods used in the United States, the risks that these activities pose to the U.S. financial system and national security, and the status of current efforts to combat these methods. In doing so, these assessments enable the U.S. Government and financial institutions to more effectively detect and combat illicit finance.

This is the first NTFRA, and the NMLRA builds and expands on a previous Treasury money laundering report issued in 2005.  The methodology for today’s reports is based on guidance set out in 2013 by the Financial Action Task Force (FATF), the international standard-setting body for anti-money laundering and counter-terrorist financing safeguards, of which the United States is a founding member.  The FATF requires all national governments to demonstrate their understanding of the money laundering and terrorist financing risks facing their financial systems.  The assessments issued today will help to inform the FATF’s ongoing review of the United States regarding our compliance with the FATF Recommendations – which are global standards focused on these issues. 

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