The Saipan Tribune reported yesterday that Commonwealth Casino Commission executive director Edward Deleon Guerrero has confirmed that Best Sunshine Live casino in Saipan is operating in compliance with U.S. Banking Secrecy and anti-money laundering laws.

Just weeks after posting their second highest rolling chip revenue ever, Best Sunshine International’s parent company, Imperial Pacific Int’l Holdings Ltd (HKEx: 01076) was moved to temporarily halt trading of shares on the Hong Kong Stock Exchange on November 15. Trading resumed at 9am the next day after experiencing an 11 percent drop.

On November 14 Bloomberg ran an article citing anonymous sources in Macau who claimed that Best Sunshine’s phenomenal success, rivaling and even surpassing the money flowing over baccarat tables in Macau was, “simply impossible if they are not inflated or facilitating money-laundering”, said the report.

The Bloomberg article followed with another four anonymous sources stating that they couldn’t understand how the tiny casino with just 16 VIP tables could be experiencing the volume it has voluntarily reported monthly to the HKEx. The article stated that another anonymous source “with knowledge of the matter” said that the U.S. Treasury’s Financial Crimes Enforcement Network had “taken notice of the activity at Best Sunshine,” according to the report.

In the company’s clarification announcement and notice of resumption of trading filed on November 16 (pdf) Imperial Pacific’s board of directors stated, “According to the Group’s internal log data, since 2016, the visitor headcounts at 10:00 p.m. of Best Sunshine casino have never been below 300. As there are only 38 gaming tables in the casino and each table is able to serve 5 to 6 customers at the same time, our service capacity has saturated. Each night, around 100 customers could not be arranged with a seat and had to queue or stand to participate,” read the filing, which also included a statement that the company was unaware of any investigation by FinCEN and that the company has, “implemented stringent internal control measures and has fully applied an anti-money laundering system to ensure compliance with all applicable US laws and regulations.”

Saipan, where Best Sunshine opened a temporary casino in July 2015, is the largest island in the Commonwealth of the Northern Mariana Islands and a commonwealth of the United States, which means the casino is subject to U.S. laws, especially in regard to finance and banking law. FinCEN is an agency under the U.S. Department of the Treasury which investigates financial crimes including money laundering. In recent times that reach has been confirmed with AML actions against the now-shuttered Tinian Dynasty Casino on a neighboring Island.

Commonwealth Casino Commission director Guerrero told the Saipan Tribune that it wouldn’t be surprising to learn that FinCEN may be looking at the casino as a routine inquiry and that, “It is not as if they’ve done something wrong, [BSI] is submitting their reports to [FinCEN].” He added that oversight is normal in the industry and that, “It is an irrelevant issue if FinCEN is doing an investigation but you don’t need to be alarmed if you are complying,” said the report.

“For Bloomberg to say something like they are under investigation is maybe a business way of addressing a competitor. FinCEN issues federal regulations under Title 31. And BSI also has its own regulatory oversight.”

Director Guerrero also offered an opinion, “If Best Sunshine Live inside a temporary casino inside a mall can outpace and outperform big name casinos is purely business. It is bad for competitors and it appears its business rivalry, since Saipan is a competitor. I can tell you the numbers are real. We are watching, documenting, and tracking it,” said the executive director.

In January, Imperial Pacific announced that Mr. Choi Fan Keung Vic (Vic Choi) had been appointed as chief compliance officer and head of legal for overseeing legal and compliance matters. Choi has over 30 years of experience in compliance management and is the former head of compliance of HSBC Bank (China) Co. Ltd.

Imperial Pacific has also selected well-known people with law enforcement and compliance experience to hold high-level seats on their board of directors. These names include a former director of the Central Intelligence Agency, James Woolsey and former senior US military judge Eugene Sullivan. Other high-profile names associated with the enterprise include Louis Freeh, the former director of the FBI, and two former U.S. Governors.

President of global capital markets at Imperial Pacific International Holdings Ltd, Shen Yan told Asian gaming industry news center GGRAsia last week that, “Most importantly, the gaming system under which we are operating is part of the U.S., and it is regulated. For our VIP patrons, they feel safe and sound, and protected,” according to a November 18 report online.

Best Sunshine has been operating in a high-end shopping mall in Garapan since a soft opening on July 26, 2015, and officially opening in November 2015. The casino, which operated without gaming taxes or outside junket operators, expects to open the first phase of their permanent casino by Chinese New Year 2017 (January 28). In an interim report to the Hong Kong borse for the six months ending June 30, 2016, Imperial Pacific stated that, “Construction of the town hotel, the Imperial Pacific Resort in Garapan, Saipan, has been progressing smoothly. An additional US$83 million has been invested in design and construction of this super luxurious resort which has brought the total investment to US$143 million by the end of first half of 2016.”

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