By J. Preston Carter, J.D., LL.M.
The Financial Crimes Enforcement Network fined Trump Taj Mahal Casino Resort $10 million for willful and repeated violations of the Bank Secrecy Act. In addition to the civil money penalty, the consent order requires the casino to conduct periodic external audits to examine its anti-money laundering BSA compliance program and provide those audit reports to FinCEN and the casino’s board of directors.
Trump Taj Mahal admitted that it failed to implement and maintain an effective AML program, failed to report suspicious transactions, failed to properly file required currency transaction reports, and failed to keep appropriate records. Many of the violations from 2012 and 2010 were discovered in previous examinations.
“Trump Taj Mahal received many warnings about its deficiencies,” said FinCEN Director Jennifer Shasky Calvery. “Like all casinos in this country, Trump Taj Mahal has a duty to help protect our financial system from being exploited by criminals, terrorists, and other bad actors. Far from meeting these expectations, poor compliance practices, over many years, left the casino and our financial system unacceptably exposed.”
According to the consent order, Trump Taj Mahal has a long history of prior, repeated BSA violations, dating back to 2003. Additionally, in 1998, FinCEN assessed a $477,700 civil money penalty against Trump Taj Mahal for currency transaction reporting violations
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