When Jennifer Shasky-Calvery, at the time the director of the Financial Crimes Enforcement Network (FinCEN), addressed attendees at G2E 2013, she brought a stern message to the industry. She called for a complete culture change in the industry with a dedication to rooting out financial crimes… or else.
Since then, Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance shortcomings have caused FinCEN to bring some civil and criminal enforcement actions against licensed casinos. To illustrate, of FinCEN’s five enforcement actions in 2016 to date, three came against casinos. This followed four FinCEN enforcement actions against casinos in 2015. So what will 2017 bring to the casino industry with respect to BSA/AML enforcement?