A Look Inside Donald Trump’s Failed Taj Mahal Casino
by Lucinda Shen, Fortune.com — Oct 10, 2016
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During Trump's 13 years as the chairman of the board between 1995 and 2009, the company made three trips through bankruptcy court, and was about to file its fourth when he left. Trump also resigned as CEO in 2004.
Now some quick-clips of the actual violations, that the Trump Taj Mahal conceded that it had repeated committed. The official FinCEN document filed, states that the series of violations go back to 2003 — well within the period of Donald Trump’s “leadership” at the casino …
UNITED STATES OF AMERICA
DEPARTMENT OF THE TREASURY
FINANCIAL CRIMES ENFORCEMENT NETWORK
pg 1
IN THE MATTER OF:
Trump Taj Mahal Associates, LLC, d/b/a
Trump Taj Mahal Casino Resort
Atlantic City, New Jersey
Number 2015-02
ASSESSMENT OF CIVIL MONEY PENALTY
I. INTRODUCTION
The Financial Crimes Enforcement Network (“FinCEN”) has determined that grounds exist to assess a civil money penalty against Trump Taj Mahal Associates, LLC d/b/a Trump Taj Mahal Casino Resort (“Trump Taj Mahal” or “the Company”),[1] pursuant to the Bank Secrecy Act (“BSA”) and regulations issued pursuant to that Act.[2]
Trump Taj Mahal admits to the facts set forth below and that its conduct violated the BSA.
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pg 2
The Internal Revenue Service, through the Small Business/Self-Employed Division (“IRS SB/SE”), examines casinos for compliance with the BSA under authority delegated by FinCEN. Since 2003, IRS SB/SE has conducted four examinations of Trump Taj Mahal that identified repeated significant violations of the BSA. In addition, in 1998, FinCEN assessed a $477,000 penalty against Trump Taj Mahal for BSA violations.
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pg 3
II. DETERMINATIONS
Trump Taj Mahal willfully violated the BSA’s program, reporting, and record keeping requirements from 2010 through 2012.[3] Importantly, many of these violations were previously cited by IRS SB/SE in previous examinations of Trump Taj Mahal since 2003. As described below, Trump Taj Mahal
(a) failed to implement and maintain an effective anti-money laundering program;
(b) failed to report suspicious activity related to several financial transactions at the casino;
(c) failed to properly file Currency Transaction Reports; and
(d) failed to keep appropriate records as required by the BSA and its implementing regulations.
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pg 6
C. Violations of Currency Transaction Reporting Requirements
The BSA and its implementing regulations require casinos to report transactions that involve either “cash in” or “cash out” of more than $10,000 during a single gaming day. 31 C.F.R.
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[Emphasis added.]
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Postscript: According to Wikipedia, the Bank Secrecy Act requires casinos “to detect and prevent money laundering” — primarily by keeping records for, and reporting on, any large daily transactions:
The Bank Secrecy Act of 1970 (or BSA, or otherwise known as the Currency and Foreign Transactions Reporting Act) requires financial institutions in the United States to assist U.S. government agencies to detect and prevent money laundering. Specifically, the act requires financial institutions to keep records of cash purchases of negotiable instruments, and file reports of cash purchases of these negotiable instruments of more than $10,000 (daily aggregate amount), and to report suspicious activity that might signify money laundering, tax evasion, or other criminal activities.
Of course as it turns out, for some “CEO businessmen”, following such simple procedures — designed to “to help protect our financial system from being exploited by criminals, terrorists, and other bad actors” — is apparently ‘just too much trouble’ to comply with.
That or just too ‘stifling’ of regulations, since once implemented, they effectively keep the high-rollers, “bad actors” away — from the easy-money games ...
What a Business model!