California card club pays $650,000 for BSA violations

FinCEN has announced its first settlement with and assessment against a “card club” gaming establishment. Oaks Card Club d/b/a Oaks Club (Oaks), of Emeryville, California admits that it violated the program and reporting requirements of the Bank Secrecy Act (BSA). Among the violations, Oaks encouraged employees to provide notice to patrons if they were about to conduct a cash transaction that would put them over the $10,000 threshold for the filing of a Currency Transaction Report, thereby possibly encouraging structured transactions. The settlement and FinCEN’s assessment require Oaks to pay a fine of $650,000 for willful violations of the BSA.