7/13/21
FINCEN PENALTIES, EXAMPLES • In 2011, a Minnesota Tribal Casino (2011) was charged with violating requirements to • Develop and implement an adequate anti money laundering program • Report transactions in currency • Report suspicious activity • Penalty: $250,000
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FINCEN PENALTIES, EXAMPLES • In 2006, an Oklahoma Tribal Casino was c harged with violating requirements to: • Develop/implement an adequate AML program • Make and retain records • Report suspicious transactions and transactions in currency • Not to structure transactions in currency • Penalty: $1,000,000 against the Tribe and $1,000,000 against the operator
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