Introduction Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”) recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the conference were the State Bar of Nevada’s Gaming Law Section, the American Gaming Association, and the University of Nevada-Las Vegas’ International Gaming Institute.
FinCEN is one of the Treasury Department’s primary agencies to oversee and implement policies to prevent and detect money laundering, and the only federal agency to oversee anti-money laundering (“AML”) compliance by casinos and card clubs. FinCEN polices for compliance with AML laws, including the Banking Secrecy Act (“BSA”), which requires certain reporting and recordkeeping by casinos and card clubs in an effort to prevent various financial and crimes. FinCEN works closely with the Internal Revenue Service (“IRS”) Small Business/Self-Employed Division, which is FinCEN’s delegated examiner for casinos and card clubs. The IRS refers significant violations of AML laws to FinCEN for enforcement action. FinCEN also receives referrals and coordinates its enforcement investigations with criminal law enforcement agencies, including the IRS-Criminal Investigations, the FBI, the Department of Justice’s Asset Forfeiture and Money Laundering Section, and U.S. Attorney’s Offices and state authorities, as well as other regulatory partners, including the Nevada Gaming Control Board.
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