LOS ANGELES– The operator of the Normandie Casino in Gardena agreed in court papers filed this morning to plead guilty to charges that it violated anti-money laundering provisions of the Bank Secrecy Act. As part of an agreement with federal prosecutors, the casino agreed to pay nearly $2.4 million for failing to report large cash transactions to federal authorities.
In a plea agreement filed this morning in United States District Court, the Normandie Club, the partnership operating the Normandie Casino, agreed to plead guilty to two felony offenses – failing to maintain an effective anti-money laundering program and conspiring to avoid reporting to the government the large cash transactions of some of the casino's “high-roller” gamblers.
Under federal law – specifically, the Bank Secrecy Act – casinos like the Normandie are required to implement and maintain programs designed to prevent criminals from using the casino to launder the large sums of cash that illegal activity can generate. For example, casinos must record and report to the government the details of transactions involving more than $10,000 by any one gambler in a 24-hour period.
“The United States has an array of anti-money laundering statutes designed to prevent criminals from using the American financial system to launder the large sums of cash generated by illegal activity such as organized crime, drug trafficking and human trafficking,” said United States Attorney Eileen M. Decker. “Casinos that fail to follow these rules are particularly vulnerable to criminals who seek to disguise illegal cash as gambling winnings.”
In the plea agreement, the Normandie admitted that its casino engaged independent gambling “promoters” to locate high-rollers and then steer those gamblers to the casino. As part of the conspiracy, “high-level personnel” at the casino agreed to avoid reporting to the government the large sums of cash certain high-rollers would bring to the casino. According to the plea agreement, the casino avoided reporting transactions related to the high-rollers by submitting Currency Transaction Reports that named the promoter instead of the gambler, by “structuring” transactions so that they appeared to be less than $10,000, or simply by failing to record large transactions.
During one six-week period in 2013, a single high-roller won more than $1 million from another party at the casino, and the casino conspired to conceal the identity of that high-roller.
Under the plea agreement, prosecutors and the Normandie agree that the casino should pay the maximum fine of $500,000 for each of the two counts, which would result in a total fine of $1 million. Additionally, the casino agreed to forfeit to the government $1,383,530, which it admitted receiving in 2013 while failing to file Currency Transactions Reports.
The Normandie also agreed to cooperate in ongoing criminal investigations, and to create, implement, and maintain an effective anti-money laundering program.
The Normandie Club is being arraigned on this case this afternoon. The formal entry of the guilty pleas will take place at a later date.
The investigation into the Normandie was conducted by IRS – Criminal Investigation and the California Department of Justice's Bureau of Gambling Control.
USAO – California, Central Updated January 22, 2016
Central District of California DOJ / 16-009 / January 22, 2016