Tinian Dynasty Case Provides A Few Reminders For Casinos

Law360, New York (August 10, 2015, 10:19 AM EDT) -- Patrick Rowan

Jeffrey Hanna In early June 2015, the Financial Crimes Enforcement Network, the U.S. Department of the Treasury's anti-money laundering enforcement arm, assessed a civil money penalty on the Tinian Dynasty Hotel & Casino, located in the Northern Mariana Islands, an archipelago to the east of the Philippines. As a U.S. territory, the Northern Marianas are subject to federal regulation.

The civil money penalty was surprising for two reasons: first, that FinCEN would investigate and fine a casino unfamiliar even to analysts who cover the gaming industry, on an island chain few knew existed; and second, for its sheer size....

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