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Financial Services Law Insights and Observations

FinCEN Acting Director Comments on Recent Casino Actions and Culture of Compliance

Federal Issues Banking Anti-Money Laundering FinCEN Compliance Combating the Financing of Terrorism

Federal Issues

On October 3, FinCEN Acting Director Jamal El-Hindi issued a statement regarding anti-money laundering and countering the financing of terrorism compliance. According to Acting Director El-Hindi, two recent actions against casinos represent failure to (i) adequately train staff at every level in the organization; and (ii) properly file - or file at all – Suspicious Activity Reports and Currency Transaction Reports. Still, Acting Director El-Hindi acknowledged that casinos in general have improved their AML compliance efforts. Acting Director El-Hindi stated that FinCEN will continue to work with casinos on their compliance efforts, and cautioned that “[a] good compliance culture is one where doing the right thing is rewarded, and where ‘looking the other way’ has consequences.”