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The reporting requirements the BSA imposes on financial institutions—including casinos—provide an invaluable source of information for law enforcement in our​.
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The U. AML regulatory regime for the gaming industry, and the recent enforcement actions which it has produced. FinCEN also pursued three large enforcement actions in , about which we have also blogged :. It found that Cantor Gaming failed to 1 provide adequate AML training for its officers and employees; 2 use all available information to identify and report suspicious transactions; and 3 maintain adequate internal controls to detect money laundering.{/INSERTKEYS}{/PARAGRAPH} In this post, we describe the U. Similar to some of the allegations in the German Report, some casinos also may attract certain individuals from across the globe who potentially are attempting to undermine certain laws in their home country, including tax reporting obligations. If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch. And, in contrast to the B. Arguably, the gaming industry remains one of the last bastions of a major business that still often deals significantly in cash — in a world increasingly driven by technology and credit. As we noted yesterday, when discussing the U. To that end, some gaming businesses may attract a disproportionate share of customers seeking to avoid ensconced BSA reporting and record-keeping requirements, including the CTR filing requirement. Although the pace of AML enforcement has been somewhat sporadic, it appears to be increasing over time in regards to the gaming industry. {PARAGRAPH}{INSERTKEYS}See Peter M.