Casino Bsa Requirements

The USA PATRIOT Act provides a textbook example of how the United States federal government expands its power. An emergency happens, legitimate or otherwise. The media, playing its dutiful role as goad for greater government oversight, demands "something must be done." Government power is massively expanded, with little regard for whether or not what is being done is efficacious, to say nothing of the overall impact on our nation's civil liberties.
No goals are posted, because if targets are hit, this would necessitate the ending or scaling back of the program. Instead, the program becomes normalized. There are no questions asked about whether the program is accomplishing what it set out to do. It is now simply a part of American life and there is no going back.
The American public largely accepts the USA PATRIOT Act as a part of civic life as immutable, perhaps even more so than the Bill of Rights. However, this act – passed in the dead of night, with little to no oversight, in a panic after the biggest attack on American soil since Pearl Harbor – is not only novel, it is also fundamentally opposed to virtually every principle on which the United States of America was founded. It might not be going anywhere anytime soon, but patriots, liberty lovers and defenders of Constitutional government should nonetheless familiarize themselves with the onerous provisions of this law, which is nothing short of a full-throttle attack on the American republic.

What’s Even in the USA PATRIOT Act?

What is in the USA PATRIOT Act? In the Michael Moore film Fahrenheit 9/11, then Rep. John Conyers cracked wise about how no one had actually read the Act and how this was in fact par for the course with America's laws. Thus, before delving into the deeper issues surrounding the PATRIOT Act, it is worth discussing what the Act actually says. Here’s a brief look at the 10 Titles in the PATRIOT Act:

• Title I: Enhancing Domestic Security Against Terrorism: This provision dramatically expands the powers of the President, the military and the intelligence community whenever the specter of "terrorism" is invoked. Bizarrely, it contains a provision condemining discrimination against Arabs, Muslims and South Asians, which seems to have very little to do with protecting Americans from terrorism.
• Title II: Enhanced Surveillance Procedures: Title II contains the meat of the Act with regard to massive, industrial-scale surveillance on the American public. Beyond the simple spying on Americans and their communications, Title II increases the ability of federal intelligence agencies to share your private communications with one another.
• Title III: International Money Laundering Abatement and Financial Anti-Terrorism Act: Not simply a section of the USA PATRIOT Act, Title III is an Act of Congress in its own right. You might have noticed how much more difficult it is to open a bank account or send a wire transfer after 9/11. You can blame this provision, which shredded banking privacy rights in the United States.
• Title IV: Protecting the Border: Other than expanding the number of federal employees (of course), the provision of the USA PATRIOT Act charged with protecting America's borders does little other than point toward paths for future action and study. It is worth noting that the weakest provision of the Act is the only one explicitly authorized by the Constitution -- protecting the border.
• Title V: Removing Obstacles to Investigating Terrorism: Title V authorizes bounties for the apprehension of alleged terrorists, broadens government power to conduct DNA analysis, allows for greater data sharing between law enforcement agencies and, perhaps most disturbingly, requires private telecommunication carriers to comply with government requests for electronic communication records whenever requested by the FBI. It also expands the power of the Secret Service to investigate computer fraud.
• Title VI: Providing for Victims of Terrorism, Public Safety Officers and Their Families: Perhaps the most innocuous portion of the USA PATRIOT Act, Title VI provides for a victims' fund for victims of terrorism and their families.
• Title VII: Increased Information Sharing for Critical Infrastructure Protection: The subtitle of this section of the Act is a rather wordy way of saying that the United States federal government is allowing for law enforcement agencies to share information across jurisdictional boundaries in an easier fashion than was previously legal. To that end, the Bureau of Justice Assistance was given a $50,000,000 budget for 2002 and a whopping $100,000,000 budget for fiscal year 2003.
• Title VIII: Strengthening the Criminal Laws Against Terrorism: Title VIII is where the rubber meets the road: What exactly is terrorism, according to the federal government? Unfortunately, this Title does little to clarify what terrorism is, instead focusing on declaring a number of actions (such as attacks on transit) as “terrorism,” regardless of intent.
• Title IX: Improved Intelligence: The section subtitled “improved intelligence” largely expands the powers and responsibilities of the Director of Central Intelligence.
• Title X: Miscellaneous: When the federal government titles a segment of a law “miscellaneous,” you know it’s going to include everything and the kitchen sink. And so it does: The definition of electronic surveillance, additional funds for the DEA in South and Central Asia, research on biometric scanning systems, a limitation on hazmat licensure and infrastructure protections are all addressed in Title X, which is a catchall for everything the federal government forgot to address in the first nine sections of the law.

Most of the provisions of the USA PATRIOT Act were set to sunset four years after the bill was passed into law. However, the law was extended first by President George W. Bush and then by President Barack H. Obama. The latter is particularly scandalous given that, at least in part, a rejection of the surveillance culture that permeated the Bush Administration was responsible for the election of Obama in 2008.

Passing the USA PATRIOT Act

Next, it’s important to remember the environment in which the USA PATRIOT Act was passed: Post-9/11. It is not the slightest bit of exaggeration to label the environment in which the PATRIOT Act was passed as “hysterical,” nor is “compliant” a misnomer for the Congress of the time. Opposition to the Act was slim and intensive review of one of the most sweeping Acts of Congress in American history was nonexistent.
All told, Congress took a whopping six weeks drafting, revising, reviewing and passing the PATRIOT Act. That’s less time than Congress typically spends on totally uncontroversial and routine bills that don’t gut the Fourth Amendment. The final vote found only 66 opponents in the House and one (Wisconsin Democrat Russ Feingold) in the Senate. The entire passage of the PATRIOT Act, from start to finish, took place behind closed doors. There were no committee reports or hearings for opponents to testify, nor did anyone bother to read the bill.
“Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism” is the bloated and overwrought full name of the bill, crafted by a 23-year-old Congressional staffer named Chris Cylke. This ridiculous name puts the focus not on the surveillance aspects or the erosion of basic civil liberties enshrined in Western society since the Magna Carta, but on patriotism. At the time of its creation, the messaging was very clear: Real patriots support massive intrusions on civil rights. As President George W. Bush said at the time, “Either you are with us, or you are with the terrorists.” This sentiment very much seemed to apply to American citizens.
While the argument that if you have nothing to hide you shouldn’t fear investigation is anathema in a Constitutional republic with regard to citizens, it should be standard operating procedure when it comes to our organs of government. If we cannot expect transparency from the United States Congress – elected officials charged with representing the will of the people and protecting the Constitution – then we certainly can’t expect it anywhere else.

The Unfortunate Growth of the USA PATRIOT Act

It’s no surprise to those in the liberty movement that given an inch, the government (in particular the military-intelligence community) took a mile. Even the nebulous definition of “terrorism,” largely centered around a long litany of acts rather than the motivation behind them, has expanded to include receiving military training from a proscribed organization (without actually committing any terrorist acts or even acts of violence of any stripe) as well as “narcoterrorism” – the latter particularly convenient, as the United States government continues its losing “War on Drugs.”
Indeed, in many ways, the War on (Some) Drugs was the template for the War on Terror. Both wars have no defined enemy, no defined terms of victory. Instead, they are waged against a nebulous concept, while enjoying bipartisan support for their ever-expanding budgets. What’s more, it didn’t take long for the Feds to start using the USA PATRIOT Act for things it was never intended for, including prosecuting the War on Drugs.
Perhaps the silliest application of the USA PATRIOT Act is the prosecution of Adam McGaughey. McGaughey maintained a fansite for the television series Stargate SG-1. The Feds charged him with copyright infringement and computer fraud. In the course of their investigation, the FBI leveraged the PATRIOT Act to get financial records from his website’s ISP. This was made possible by the USA PATRIOT Act amending the Computer Fraud and Abuse Act, allowing for search and seizure of ISP records.
The New York Times discovered in September 2003, that the USA PATRIOT Act was being used to investigate alleged drug traffickers without what would otherwise be sufficient probable cause. These were investigations into non-terrorist acts using a law ostensibly designed to investigate terrorism. There was some suspicion that the Act was being used to investigate crimes occurring before the Act was passed, violating the ex post facto clause of the United States Constitution.
In one of the biggest power grabs (excluding virtually everything we know from Edward Snowden – more on that below), the FBI sent tens of thousands of “national security letters” and procured over one million financial records from targeted businesses in Las Vegas. These businesses were primarily casinos, car rental bureaus and storage spaces. The data obtained included financial records, credit histories, employment records and even people’s personal health records.
The FBI maintains and databases this – and, indeed, all information collected through the USA PATRIOT Act – indefinitely. In the good old days before the PATRIOT Act, the Feds were compelled to destroy any evidence they collected on someone later found not guilty of a crime. Note that the aforementioned data collection brought to public attention by Edward Snowden (which, again – we’re getting to that) falls under this provision. Not only is the government collecting obscene amounts of private and personal information about you, they’re also storing it indefinitely with no plans to stop.
What’s more, the FBI has approached public libraries to turn over the records for specific terminals, collecting information not about specific users who might be under investigation, but about anyone who has ever used the computer at the public library. Libraries, to their credit, have been very much at the forefront of resistance against the PATRIOT Act, with some litigating compliance despite operating on small budgets and others posting “canary letters,” which effectively say “The FBI Hasn’t Been Here Yet.” The removal of such a letter would warn patrons that the FBI has been sniffing around in their records.
Indeed, the greatest criticism of the PATRIOT Act is the simplest and perhaps most obvious: Why does an Act ostensibly passed to fight terrorism so drastically expand the government’s power to investigate virtually everyone else? The PATRIOT Act is not merely unconstitutional, it is an unprecedented expansion of state power in the Anglosphere, a culture based on restricted government and the primacy of individual rights.
An excellent example of this is the Foreign Intelligence Surveillance Act (FISA) expansion. Most people are familiar with the term “FISA court,” but very few people actually know what it is – a special federal court created under the Carter Administration that grants approval of electronic surveillance of both citizens and resident aliens in the event that they are accused of acting in the service of a foreign power. The last part of this sentence is very important: The FISA courts are not simply for allowing surveillance of anyone that it might be expedient to collect information about. The scope of their powers is very, very limited.
Or was.
The PATRIOT Act lowered the burden of evidence required to obtain a FISA warrant for electronic surveillance and expanded the overall scope of the FISA courts. Any savvy federal agent can now drape his charges in the garb of (what else?) “national security” and obtain electronic surveillance privileges hitherto only dreamed of by investigators. FISA courts have become pliant tools in the hands of the Feds, gladly approving their requests to monitor phone and internet surveillance, as well as access to medical, financial and educational records.

The Future of the USA PATRIOT Act

Do we still need the PATRIOT Act? Did we ever? All laws are certainly a product of their times. But this seems much more acutely true of the USA PATRIOT Act, which was passed in a rush and under duress without due consideration.
Particularly in light of the revelations from Edward Snowden – that the government is spying on everything they possibly can – it’s worth asking if there’s any walking back. He points out that the police state apparatus was originally for drug dealers, then for terrorists, but ultimately ended up being applied to anyone and everyone.
What’s more, Bob Bullard notes another frightful aspect of the USA PATRIOT Act: Terrorism-related cases are not subject to the Freedom of Information Act. This means that there is little or no oversight. There is no surer hallmark of a police state than an all-powerful domestic surveillance agency with no transparency or oversight. While the USA PATRIOT Act might not create an American Stasi as such, it certainly paves the way for one.
Continue reading The USA PATRIOT Act: The Story of an Impulsive Bill that Eviscerated America's Civil Liberties at Ammo.com.

I have been studying for the CAMS 6 Exam for the past 5 weeks, and during the last 2 weeks, I did a lot of research on Reddit which helped me get a better understanding of the exam format as well as other people’s perspectives/experiences etc. As I passed the CAMS 6 Exam earlier this morning, I wanted to give back to the Reddit community and share some general feedback/tips as well as answer some frequently asked questions to help future exam takers, as I understand firsthand how nerve wrecking preparing for a major exam can be.
Here are some frequently asked questions (questions that I also personally had when searching Reddit) and feedback on common external resources used:
-Exam Preparation time : 5 weeks, primarily weekends, 3-5 hours each Saturday and Sunday, and listening to Audio Book on my drive to work and back (50 minutes aggregate per day, not every day though)
-BSA/Compliance experience : 3 years (12 in banking in general, e.g. 9 years mostly as a Licensed Personal Banker)
-Resources and study plan: I read the entire study guide once while taking notes (for mental retention only, as I personally did not refer back to these notes afterwards), while reading the study guide, as mentioned above I would also listen to the audio version when I was driving to work and back. After I finished the study guide I completed the online module (this was about 8-9 days prior to the exam). Afterwards I took the study guide practice test at the end, scored 108, and reviewed the 12 questions I missed to reinforce deficiencies. Lastly, I reviewed ALL the flash cards about 5 days prior to the exam.
-External Resources: I took the AML Expert Free sample test and AML Assassin paid practice test both in the last 5 days leading to the exam.
-Practice tests vs Actual Exam: Neither the AML Expert test, nor the practice test at the end of the study guide nor the AML Assassin test, are similar to the Actual Exam. The actual Exam is worded in its very own way, which is why you MUST understand the material, not just memorize anything. You need to understand the material and be able to apply it, because the actual exam writers definitely got creative with their questions and answers choices, HOWEVER, common sense alone and good judgment will help you answer several questions, just make sure you read every question carefully AT LEAST twice. After having taken the exam I would probably not recommend the AML Expert as I felt some of their questions were incorrect and quite frankly, confusing. As far as the AML Assassin, it’s a more difficult test than the actual Exam, and that’s not something that will necessarily help you, because (1) most of their questions were in a different format (probably outdated format since I know this test was created several years ago and the questions for the most part haven’t been updated) (2) unnecessarily complex (some of their questions had 8 possible choices of answers to choose 4-5 correct) the real exam had no more than 5 possible choices to choose 3 correct, and (3) covered many topics that were not mentioned in the study guide nor in the actual exam at all. So the AML Assassin, I’m not gonna say, don’t take it, it may help you prepare more if you are the type of person that learns from taking multiple practice tests, and likely given it’s unnecessary difficulty level, if you pass it, you will also more than likely pass the real thing, but is it necessary? Not at all.
For comparison, I scored 108 in the study guide practice test, 91 in the AML Assassin and 103 in the actual ACAMS Exam. My scores were in line with most of the feedback in Reddit, your actual exam score will likely be somewhere in the middle between the study guide test score and the AML Assassin test score.
The Exam itself, I’m not going to tell you study this or study that, because from what I read here there seems to be different versions, some people get a lot of Chapter 2, some others get a lot of Chapter 3 etc. personally, I got a little bit of everything, although primarily situational questions such as scenarios identifying the highest money laundering risks and red flags/typologies etc for the many different industries (Real estate, casino, MSBs, Precious metals dealers etc) as well as situational questions regarding what would you do as a compliance officer in such and such situations (including Compliance Program requirements/standards etc), after this which I would say represented probably about 50% of the exam, the rest was OFAC and Investigations/SAR processes including procedures for communication and information sharing with Law Enforcement (probably about 20%). The other 30% was just spread out in general, little bit of FATF more than the rest but also questions about TBML, BMPE, Egmont, Basil, Wolfsberg, FSRBs, EU Directives, etc.
Overall, it’s not an easy exam by any means, it requires preparation, it’s not an exam you can just probably “swing” regardless of your experience or lack thereof, but using common sense, as cliche as it sounds, will go a long way in answering questions correctly.
I tried to cover most of the questions that I had myself, none of which had been covered in a single Reddit post before.
If you have any additional questions, or anything at all you want to ask, fire away, I would love to help out.

From Reuters

Danske Bank, Denmark’s largest lender, is under investigation in several countries, including the United States, Denmark, Britain and Estonia, over suspicious payments totaling 200 billion euros ($220 billion) which were moved through its tiny Estonian branch during the period Rehe was in charge.
Rehe’s death is likely to complicate investigations into Danske Bank’s Estonian operation, including by U.S. authorities.
The former banker’s importance in investigating the case was highlighted by the fact that he had been quizzed, as a witness, by Estonian prosecutors.
Danske Bank’s is the largest in a series of European money laundering scandals, stretching from Latvia to Sweden.
And in a sign of the wider ramifications of the case, Frankfurt prosecutors said they had raided Deutsche Bank’s headquarters in the German financial capital in relation to Danske Bank. Deutsche Bank said it was cooperating.

The time period that Rehe oversaw the bank coincided with Trump making lots of cash purchases and receiving tons of money from Russia.
Don Jr said there was tons of money pouring in from Russia in 2008.
Around 2006, the Trump Org started paying cash for properties.

In the nine years before he ran for president, Donald Trump’s company spent more than $400 million in cash on new properties — including 14 transactions paid for in full, without borrowing from banks — during a buying binge that defied real estate industry practices and Trump’s own history as the self-described “King of Debt.”
Instead, Eric Trump said, the firm’s existing businesses — commercial buildings in New York, licensing deals for Trump-branded hotels and clothes — produced so much cash that the Trumps could tap that flow for spending money.
Trump’s lavish spending came at a time when his business was leaning largely on one major financial institution for its new loans — Deutsche Bank, which provided $295 million in financing for big projects in Miami and Washington.
The year before he launched his campaign for president, Trump made the two most expensive all-cash purchases that The Post found in its review. In 2014, he shelled out $79.7 million for the huge golf resorts in Doonbeg, Ireland, and Turnberry, Scotland — both of which were losing money at the time.
The Trump Organization pursued pricey renovations of both courses, during which time the properties have continued to suffer losses. Under Trump, the two courses are at least $240 million in the hole so far, according to British and Irish corporate records.

The house in FL sold to the Russian Oligarch was purchased during this time.
Importantly, Trump's casinos were fined multiple times for not following rules to prevent money-laundering.
https://www.reuters.com/article/trump-ent-trumptajmahal-moneylaundering-idUSL1N0VL2L120150211
https://www.cnn.com/2017/05/22/politics/trump-taj-mahal/index.html

According to a dozen anti-money laundering experts, casinos often run into these problems. But getting caught with 106 violations in the casino's opening years is an indicator of a serious problem, they said.
The violations date back to a time when the Taj Mahal was the preferred gambling spot for Russian mobsters living in Brooklyn, according to federal investigators who tracked organized crime in New York City. They also occurred at a time when the Taj Mahal casino was short on cash and on the verge of bankruptcy.

The official statement from FinCEN

Trump Taj Mahal, a casino in Atlantic City, New Jersey, admitted to several willful BSA violations, including violations of AML program requirements, reporting obligations, and recordkeeping requirements. Trump Taj Mahal has a long history of prior, repeated BSA violations cited by examiners dating back to 2003. Additionally, in 1998, FinCEN assessed a $477,700 civil money penalty against Trump Taj Mahal for currency transaction reporting violations.

TLDR: A senior banking official, who oversaw an Estonian branch of Danske Bank, which was involved in ~$220 billion in money laundering during roughly the same decade-long period that Trump used cash to buy properties, was found dead after speaking with prosecutors and investigators. It is highly likely that the properties purchased with cash are laundromats for Russian Oligarch money as previous Trump properties have been/are.

FinCEN Fines Trump Taj Mahal Casino Resort $10 Million for Significant and Long Standing Anti-Money Laundering Violations
WASHINGTON, DC – The Financial Crimes Enforcement Network (FinCEN) today imposed a $10 million civil money penalty against Trump Taj Mahal Casino Resort (Trump Taj Mahal), for willful and repeated violations of the Bank Secrecy Act (BSA). In addition to the civil money penalty, the casino is required to conduct periodic external audits to examine its anti-money laundering (AML) BSA compliance program and provide those audit reports to FinCEN and the casino’s Board of Directors.
Trump Taj Mahal, a casino in Atlantic City, New Jersey, admitted to several willful BSA violations, including violations of AML program requirements, reporting obligations, and recordkeeping requirements. Trump Taj Mahal has a long history of prior, repeated BSA violations cited by examiners dating back to 2003. Additionally, in 1998, FinCEN assessed a $477,700 civil money penalty against Trump Taj Mahal for currency transaction reporting violations.
"Trump Taj Mahal received many warnings about its deficiencies," said FinCEN Director Jennifer Shasky Calvery. "Like all casinos in this country, Trump Taj Mahal has a duty to help protect our financial system from being exploited by criminals, terrorists, and other bad actors. Far from meeting these expectations, poor compliance practices, over many years, left the casino and our financial system unacceptably exposed."
Trump Taj Mahal admitted that it failed to implement and maintain an effective AML program; failed to report suspicious transactions; failed to properly file required currency transaction reports; and failed to keep appropriate records as required by the BSA. Notably, Trump Taj Mahal had ample notice of these deficiencies as many of the violations from 2012 and 2010 were discovered in previous examinations.
Director Shasky Calvery expressed her appreciation to the Internal Revenue Service, Small Business/Self-Employed Division, which performed the examinations of Trump Taj Mahal, for their contributions to the investigation and for their strong partnership with FinCEN. She also thanked the Commercial Litigation Branch of the U.S. Department of Justice for their assistance with this enforcement action.
Trump Taj Mahal petitioned for bankruptcy in September 2014. That bankruptcy remains pending. The Bankruptcy Court approved of Trump Taj Mahal’s settlement on March 4, 2015.
FinCEN seeks to protect the U.S. financial system from being exploited by illicit actors. Its efforts are focused on compromised financial institutions; third-party money launderers; transnational organized crime; terrorist and other security threats; significant fraud; and threats to cyber security. FinCEN has a broad array of enforcement authorities to target both domestic and foreign actors affecting the U.S. financial system.
SOURCE: https://www.fincen.gov/news_room/nhtml/20150306.html