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Casino Fails to Report Millions in Cash

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Casino Fails to Report Millions in Cash

SAIPAN, CNMI – Hong Kong Entertainment (Overseas) Investments Ltd., doing business as Tinian Dynasty Hotel & Casino (“TDHC”), has been ordered to forfeit $2,500,000 in a landmark case involving failure to report millions in cash transactions.

According to sources, the casino, which is one of the largest in the Northern Mariana Islands, failed to file Currency Transaction Reports (CTRs) for transactions exceeding $10,000 in cash, as required by law. The U.S. Attorney’s Office alleges that TDHC’s actions were a deliberate attempt to circumvent federal regulations and conceal illicit activities.

“This forfeiture is the culmination of a year-long investigation. The persistent and dedicated efforts of IRS Criminal Investigators were instrumental in recovering these funds,” said Alicia A.G. Limtiaco, United States Attorney for the Districts of Guam and the Northern Mariana Islands.

U.S. District Court Chief Judge Ramona V. Manglona ordered the casino’s rights, title, and interest in the $2,500,000 to be vested with the United States of America. The judge’s ruling was a significant blow to TDHC, which had entered into a Non-Prosecution Agreement with the government requiring the casino to forfeit millions in proceeds traceable to criminal violations.

The agreement also obligates TDHC to fully cooperate with the United States in ongoing criminal investigations and to comply with federal reporting and other regulatory requirements. The United States – in its sole discretion – can rescind the Agreement and initiate criminal proceedings should the Government determine that TDHC has failed to comply with any provision of the Agreement.

“The Bank Secrecy laws were enacted to curtail the movement of ill-gotten gains through our financial institutions. When one of those entities shirks their duty and fails to comply with the law requiring the examining and reporting of certain financial transactions, it creates an entry point for would-be criminals to circumvent rules intended to frustrate and detect their criminal enterprises,” stated Special Agent in Charge Teri Alexander of IRS Criminal Investigation.

The case against TDHC was brought under the Bank Secrecy Act (BSA), which requires financial institutions and certain businesses, including casinos with annual gaming revenue in excess of $1 million, to be vigilant in detecting and reporting activity that may indicate that money laundering, or other financial crimes, are being committed.

The U.S. Attorney’s Office and the IRS have vowed to continue monitoring the gaming industry to ensure the integrity of our financial markets. The case serves as a stark reminder of the consequences of failing to comply with federal regulations and highlights the importance of cooperation between law enforcement agencies in preventing and investigating financial crimes.

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