WASHINGTON—The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) assessed a $900,000 civil money penalty against Lake Elsinore Hotel and Casino (Lake Elsinore) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations.
“Lake Elsinore operated for years without the most basic AML controls, putting its customers and the U.S. financial system at risk and denying law enforcement information on suspicious activity,” said FinCEN’s Director Andrea Gacki. “This action should serve as a reminder that all financial institutions—regardless of their type or size—must comply with their obligations under the BSA and FinCEN’s regulations.”
As part of its resolution with FinCEN, Lake Elsinore admitted to willful violations of the BSA, including failing to implement and maintain an effective AML program, failing to file currency transaction reports (CTRs) and suspicious activity reports (SARs), and certain recordkeeping failures. Lake Elsinore’s willful violations of the BSA, which continued for over four and a half years, resulted from decisions made by the card club’s management. In addition to the civil money penalty, Lake Elsinore will also be subject to an AML program review.
FinCEN appreciates the close partnership with its partners from the state of California on this matter. This action will be FinCEN’s first resolution alongside the California Department of Justice – Bureau of Gambling Control (CA-BGC).
FinCEN’s Enforcement and Compliance Division is responsible for investigating serious violations of the BSA. For additional information regarding the facts and circumstances associated with this enforcement action, including the specific BSA violations and their underlying causes, please see the Consent Order between FinCEN and Lake Elsinore.