The US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced this week that it had imposed a $75 million fine on the Tinian Dynasty Hotel and Casino, which is located in the Commonwealth of the Northern Mariana Islands (CNMI). These pacific islands come under the rule of the United States and the record $75 million fine was imposed by FinCEN because they believed that the Tinian Dynasty Hotel and Casino deliberately violated the Bank Secrecy Act and encouraged its employees to breach legal rules on a regular basis.

The authorities were suspicious about numerous financial transactions being conducted at the casino and decided to go undercover by posing as VIP gamblers. These gamblers spent large sums of money at the casino and requested casino staff not to report their high level bets or keep any financial record of their spending. Casino staff were happy to oblige and did not question or deny the requests of these VIP gamblers.

The Tinian Dynasty Hotel and Casino which is owned by Hong Kong Entertainment (Overseas) Investments Ltd had no clear procedure in place that required its staff to maintain financial records of large money transactions nor were they sufficiently trained to spot suspicious activity or gamblers. The investigation also revealed that the casino did not have a strong anti-money laundering system in place that would allow them to prevent unlawful financial transactions.

FinCEN stated that the policy and procedures adopted by the casino had huge loopholes that could be easily exploited for money-laundering, illegal wire transfers and fostered corruption within the casino.

In a statement, FinCEN director Jennifer Shasky Calvery said “Tinian Dynasty didn’t just fail to file a few reports… The casino operated for years without an AML programme in place. It failed to file thousands of CTRs and its management wilfully facilitated suspicious transactions and even provided helpful hints for skirting and avoiding the laws in the U.S. and overseas. Tinian Dynasty’s actions presented a real threat to the financial integrity of the region and the U.S. financial system.”