Cantor Gaming pays $22.5MM for AML violations
FinCEN has assessed a civil money penalty of $12 million against CG Technology, L.P., doing business as Cantor Gaming, for egregious and systemic violations of the anti-money laundering (AML) provisions of the Bank Secrecy Act (BSA). FinCEN’s analysis of reports filed under the BSA and information obtained from a 2010 examination by the Internal Revenue Service’s Small Business/Self-Employed Division (IRS SB/SE), as well as a 2014 follow up audit by FinCEN, support this action. Additional supporting information concerning illegal gambling and money laundering surfaced stemming from a criminal investigation and indictment of 25 individuals, known as the “Jersey Boys,” conducted by the U.S Attorney’s Office for the Eastern District of New York.
Cantor Gaming admitted that it willfully violated the BSA and its implementing regulations. These violations are described in an accompanying Statement of Facts. Cantor Gaming facilitated high risk and high dollar wagering on sporting events representing over 30% of all sports wagers in Nevada. At the same time, it failed to have an appropriate AML program in place. Cantor Gaming failed to have sufficient internal controls and mandatory independent audits; it failed to have sufficient AML training for its officers and employees; and it failed to use all available information to detect and report suspicious transactions. In addition to these extensive, years-long program violations, Cantor Gaming failed to properly and timely report currency transactions. Cantor Gaming also failed to file required suspicious activity reports (SARs) on several transactions, including transactions by customers who were involved in blatantly suspicious activity, those who were involved in criminal activity, and those who had no legitimate source of funds. And finally, Cantor Gaming committed thousands of recordkeeping violations, including by failing to keep required records on its highest-volume patron who placed more than $300 million in wagers between 2010 and 2013.
FinCEN’s assessment is concurrent with the U.S. Attorney’s Offices for the Eastern District of New York and District of Nevada’s announcement of a non-prosecution agreement with Cantor Gaming. In that settlement, Cantor Gaming resolved possible criminal charges, agreeing to a forfeiture of $6 million and a criminal fine of $10.5 million. Six million dollars of the criminal fine and forfeiture will be credited to partially satisfy FinCEN’s $12 million civil money penalty.