In a guest column they penned for Law360, McGuireWoods lawyers J. Patrick Rowan and Jeffrey M. Hanna discuss an $8 million civil penalty the
Financial Crimes Enforcement Network imposed on Caesars Palace for violations of the Bank Secrecy Act. Essentially, FinCEN found that the casino failed to
develop and implement a required anti-money laundering program and failed to report suspicious activity among its patrons.
Extrapolating, Jeff and Pat suggest that the enforcement action be considered a reminder to casinos and the rest of the regulated community to be aware of
their customers’ practices, and recognize the importance of training personnel to identify and report suspicious activity in their establishments.
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