Tinian Dynasty to forfeit $2.5 million for reporting violations

Hong Kong Entertainment (Overseas) Investments Ltd., owner of Tinian Dynasty Hotel and Casino is to forfeit $2.5 million for failing to document over $138 million in reportable cash transactions, Marianas Variety reports.

Alicia A.G. Limitiaco, United States attorney for the Districts of Guam and the Northern Mariana Islands announced the successful forfeiture, which represents the largest forfeiture in NMI history. The agreement also obligates Tinian Dynasty to fully cooperate with the United States in ongoing criminal investigations and to comply with reporting requirements.

Federal law requires financial institutions to certain businesses including casinos to detect and report activity that may indicate money laundering or other financial crimes. Casinos are required to file a “Currency Transaction Report for Casinos” for transactions that involve more than $10,000 in cash.

On Nov. 20, 2014, a federal grand jury charged Tinian Dynasty with one count of conspiracy to fail to file a currency transaction report, one count of failure to file a SAR, and one count of failure to maintain an effective anti-money-laundering program.

According to filings, Tinian Dynasty did not disclose individuals whose gambling activities should have triggered a BSA report, and failed to document over $138 million in reportable cash transactions from Oct. 1, 2009 to Apr. 25, 2013.