FinCEN's Caesars Penalty A Cautionary Tale For Casinos
Law360, New York (September 17, 2015, 6:01 PM EDT) -- J. Patrick Rowan
Jeffrey M. Hanna
Last week, the Financial Crimes Enforcement Network announced a consent agreement that imposed an $8 million civil penalty against Desert Palace Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in U.S. Securities and Exchange Commission filings in late 2013. The investigation grew out of a 2012 audit performed by FinCEN's examiner, the Internal Revenue Service Small Business/Self-Employed Division (IRS SB/SE).
In addition to the penalty, the agreement made factual determinations and imposed "undertakings" — remedial measures — intended to bring Caesars into compliance with the requirements of the Bank Secrecy Act and its implementing...
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