July 15, 2016
The Financial Crimes Enforcement Network (FinCEN) today announced a settlement with and a $2.8 million assessment against Hawaiian Gardens Casino, Inc. d/b/a The Gardens Casino, of Hawaiian Gardens, California. The Gardens, a card club, admitted that it violated the Bank Secrecy Act’s (BSA) program and reporting requirements and has agreed to future undertakings, including periodic independent reviews to examine and test its BSA AntiMoney Laundering (AML) program.
The Internal Revenue Service (IRS) examines card clubs for compliance with the BSA pursuant to authority delegated by FinCEN. In 2011 and 2014, IRS examined The Gardens and identified significant BSA violations. Many violations uncovered in 2011 were left unaddressed in 2014, despite the IRS findings in 2011 and despite the fact that the Gardens’ independent consultant identified many of these problems in 2013. From September 1, 2009 through the present, The Gardens failed to implement and maintain an effective AML program, failed to report large cash transactions, failed to file many suspicious activity reports (SARs), and failed to keep certain required records.