Preparing Your Property for a Title 31/AML IRS Compliance Examination
5/3/2016
What to Do • If you are a Tribe currently operating in the marijuana industry: • Prohibit those employees from gambling in the Casino. o We typically do this already with slots, table games, finance, etc.
• This is most extreme reaction, but protects the Casino from AML ramifications.
Recent Updates
Enforcement Actions o
•
Trump Taj Mahal – 3/6/15 • $10 Million
o Trinian Dynasty Hotel & Casino – 6/3/15 • $75,000,000 • George Que, VIP Services Manager – Barred from Gaming Industry in August 2014 o Caesar’s Entertainment – 9/8/15 • $8 Million – FinCEN • $1.5 Million – State of Nevada o Oaks Card Club – 12/17/15 • $650,000 o Sparks Nugget – 4/5/16 • $1 Million • More?
BlueBird, CPAs
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