Casino Owned by Presidential Candidate Donald Trump Violated US Anti-Money Laundering Laws Repeatedly

Federal law enforcers fined gaming company more than $10 million for leaving “financial system unacceptably exposed” to criminal activity

Republican presidential contender Donald Trump has billed himself as a law-and-order candidate and even claims his opponent, Democrat Hillary Clinton, should not be allowed to run for high office because of her alleged past crimes — although she had never been indicted, much less convicted of a crime.

Trump, as an owner and a top executive overseeing Trump Taj Mahal casino in Atlantic City, New Jersey, however, flouted U.S. money laundering laws for years, contributing to a decision last year by the federal Financial Crimes Enforcement Network, or FinCEN, to fine the casino $10 million for “willful and repeated violations” of U.S. law. Those violations involved transgressions of the Bank Secrecy Act (BSA, also known as the Currency and Foreign Transaction Reporting Act), which, in part, is designed to prevent money laundering by terrorist groups, corrupt foreign leaders and criminal organizations.

“Trump Taj Mahal has a long history of prior, repeated BSA violations cited by examiners dating back to 2003,” states a FinCEN press release announcing the $10 million fine against Trump Taj Mahal last March. “Additionally, in 1998, FinCEN assessed a $477,700 civil money penalty against Trump Taj Mahal for currency-transaction reporting violations.”

The casino, according to FinCEN, admitted to breaking the law by failing to:

• Implement and maintain an effective anti-money laundering program;
• Report suspicious transactions;
• File currency transaction reports for cash transactions involving more than $10,000; and
• Keep required records as mandated by the BSA.

“The IMF [International Monetary Fund] and World Bank estimate that 3 percent to 5 percent of global GDP [gross domestic product] is laundered — approximately $2.17 [trillion] to $3.61 trillion annually,” the U.S. State Department reports on its website. “Narco-traffickers, kleptocrats, transnational organized criminals are but three significant entities that engage in the effort to disguise their illegal proceeds ….

“When criminals (including corrupt officials) and organized crime syndicates disguise the illicit nature of their proceeds by introducing them as legal funds into the stream of legitimate commerce and finance, they not only are clandestinely hiding their ongoing affairs but they are also tainting the international financial system and eroding public trust in its integrity.”

Trump Taj Mahal opened in 1990 under the ownership and control of current presidential candidate Trump and since then has been part of four bankruptcy reorganizations, which took place in 1991, 2004, 2009 and 2014.

The casino emerged from its final bankruptcy earlier this year under new ownership, and Trump relinquished his remaining 10 percent interest in the business. The casino closed its doors earlier this month after negotiations between its new owner, billionaire Carl Icahn, and union employees broke down, leaving some 3,000 casino workers unemployed.

With each bankruptcy, Trump’s ownership and control of Trump Taj Mahal was reduced. Trump, however, from 1995 to 2009 served as chairman of the casino’s parent company, Trump Hotels and Casino Resorts, which was renamed Trump Entertainment Resorts in 2004. He also served as the parent company’s chief executive officer from 2000 to 2005 — a period that includes years when FinCEN said multiple BSA violations occurred at the casino. Trump also was the owner and operator of Trump Taj Mahal in 1990 and 1991, which is when the BSA violations cited in the 1998 FinCEN penalty took place.

In fact, one of the more glaring money-laundering threats that played out at the casino under now-presidential candidate Trump’s leadership was the employment of a high-level executive allegedly linked to organized crime. Danny Leung, Trump Taj Mahal’s vice president for marketing from 1990 until early 1993, was identified in 1992 by a Senate subcommittee as “an associate of the 14K Triad,” a Hong Kong-based criminal organization involved in murder, money laundering, extortion and narco-trafficking.

The New York Daily News reported in 1995 that, according to New Jersey regulators, Leung allegedly “flew in 16 Italian organized crime figures from Canada who stole more than $1 million from the [Trump Taj Mahal] casino in a credit scam.” The newspaper also indicated that the incident was “never reported” because Trump didn’t file charges.

In announcing the $477,700 fine against Trump Taj Mahal in 1998 (again, a penalty stemming from BSA violations that took place in 1990 and 1991) then-FinCEN Director Stanley E. Morris said:

“Casinos are cash-intensive businesses, and many offer a wide variety of financial services, similar to banks. Without effective safeguards, they may be vulnerable to money laundering."

Anti-money laundering industry expert and former U.S. prosecutor Charles Intriago, principal of Intriago Advisors, says “laundering dirty money is easy to do in a casino” that doesn’t have proper safeguards in place, as was the case for years at Trump Taj Mahal, including under Trump’s ownership and executive leadership.

Intriago told Narco News in a recent interview that if the violations of U.S. anti-money laundering laws are serious enough, the US Treasury Department, which oversees FinCEN, can go beyond civil penalties and make a criminal referral to the US Department of Justice (DOJ) — although he says such referrals are very rare. It is not clear if a criminal referral was ever made to DOJ in the case of Trump Taj Mahal as a consequence of its numerous violations of US anti-money laundering laws over the years. Such referrals are not public record, Intriago says.

FinCEN spokesman Stephen Hudak told Narco News that he could not comment on the Trump Taj Mahal case beyond what is in the documents already made public by his agency. Trump’s press secretary, Hope Hicks, did not respond to a request for comment.

Trump Taj Mahal does not represent the first time current presidential candidate Trump has been associated with business operations accused of failing to adhere to US anti-money laundering laws.

In 2005, Trump cut a business deal with a company called Bayrock Group LLC to build a hotel in Moscow. Although that project didn’t pan out, Trump did later team with Bayrock on the Trump SoHo hotel-condominium development in New York City.

That Trump project in 2007 received a shot in the arm, along with several other Bayrock projects, in the form of a $50 million dollar investment from an Icelandic investment firm. That company, the FL Group, was backed by Russians “who were in favor with [Russian President Vladimir] Putin,” pleadings in a lawsuit against Bayrock allege.

Bayrock is the target of a pending civil-racketeering lawsuit filed by the company’s former finance director and another employee. The plaintiffs allege in the pleadings that Bayrock is “covertly mob-owned and operated” and accuse the company’s principals of engaging in “money laundering, conspiracy, bribery, extortion and embezzlement.”

The failure of U.S. law enforcers to bring criminal charges against large financial institutions, including casinos, and their executives in cases of flagrant violations of anti-money laundering laws represents a longstanding double-standard in the US justice system. It is a double-standard that may well have worked to the advantage of Trump Taj Mahal’s executive leadership, which over the course of years failed to assure that the casino complied with those laws.

Mega-financial institutions Citigroup, JP Morgan Chase & Co., Wachovia (acquired by Wells Fargo in 2009), HSBC Holdings, ING Bank, Standard Chartered, American Express Bank International, and not a few others, for example, all have been accused over the past decade of failing to comply with US anti-money laundering laws — thereby enabling, collectively, hundreds of billions of dollars of suspicious transactions to move through the banking system absent adequate monitoring or oversight.

Yet not one these banks, nor any of their top executives, has been hit with criminal sanctions.

“All financial crime has a money laundering component,” Intirago said in a previous interview with Narco News. “… If you’re an individual, and get caught, you get hammered.

“But if you’re a big bank [or casino], and you’re caught moving money for a terrorist or drug dealer, you don’t have to worry. You just fork over a monetary penalty, and then raise your fees to make up for it.”

Consequently, the fact that criminal charges were apparently never pursued against Trump Taj Mahal or its executive leadership, including Trump, doesn’t mean that serious harm wasn’t done by the casino’s failure to comply with US anti-money laundering laws.

“Trump Taj Mahal received many warnings about its deficiencies,” said current FinCEN Director Jennifer Shasky Calvery in a prepared statement. “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 [dating back to 1998] left the casino and our financial system unacceptably exposed.”

Prior Stories in the Series

The Donald and the Snitch

Trump Campaign Is Still Playing Russian Roulette With Foreign Policy

Lawsuit Threatens to Expose Trump Campaign’s White Supremacist Links

Donald Trump’s Past Lobbying Exploits Paint a Picture of a Deft Washington Insider

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