FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership requirements for financial institutions is expected to be released before the end of the year. FinCEN’s proposal in this area will have a significant impact on companies subject to AML...
AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go (view episode here) – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of the end of the pipe, and so on — you will get the picture. We all know about the...
FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML compliance. In March 2015, FinCEN imposed a $10 million penalty on Trump Taj Mahal in Atlantic City, New Jersey, for violations of the Bank Secrecy Act (BSA). In addition to this hefty...
