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US: FinCEN Issues Artichoke Joe’s Casino with Civil Money Penalty for Violating AML Laws

Latest update: May 3, 2018. FinCEN has released a new assessment on the matter of Artichoke Joe’s Casino (AJC) and its violations of the Bank Secrecy Act (BSA), and regulations issued pursuant to that act. Upon AJC’s consent to the assessment, FinCEN decided to impose a penalty of $8m; however, AJC will not have to pay $3m of the penalty if it complies with all the undertakings set forth by FinCEN and included in its new assessment. These undertakings include:

  • ACJ must, within 60 days from the date of this assessment, hire a qualified and independent consultant, approved by FinCEN, who will be responsible for assessing the effectiveness of the AML program that the company has in place.
  • Continue to employ such an independent consultant, who will be in charge of the ongoing monitoirng of the company’s compliance with the requirements in the BSA and the regulations thereof. 

In case AJC fails to prove in writing its compliance with all its undertakings, the enitre amount of the penalty imposed will be due. 

The new assessment is available here.

 

On November 17, 2017 the Financial Crimes Enforcement Network (FinCEN) announced that it had issued Artichoke Joe’s (AJC), a California

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