Major Abuse of Power

Trump Taj Mahal: $10 Million FinCEN Fine for Willful Anti-Money-Laundering Violations

FinCEN found that the Trump Taj Mahal had, over the course of years, failed to file Currency Transaction Reports (CTRs) on large cash transactions as required under the Bank Secrecy Act, failed to maintain adequate Suspicious Activity Report (SAR) programs, and failed to maintain basic anti-money-laundering controls. The violations were documented across thousands of transactions. FinCEN described the violations as 'willful' — meaning the casino knew what was required and did not comply. The $10 million fine was FinCEN's largest-ever against a casino; the previous Trump casinos had also faced regulatory action.

Overview

The Financial Crimes Enforcement Network does not issue $10 million fines for oversight failures. It issues them for "willful and repeated" violations — a legal standard meaning the entity knew what was required and chose not to comply.

The Trump Taj Mahal casino failed to file thousands of required reports on suspicious cash transactions. It failed to maintain anti-money-laundering controls whose purpose is to prevent criminals from using casinos to convert illegal cash into clean money. It had been fined before.

What AML Controls Do

Bank Secrecy Act requirements in the casino context exist because casinos are natural venues for money laundering: cash in, chips, play, cash out — converting the provenance of funds. Currency Transaction Reports and Suspicious Activity Reports are the regulatory infrastructure that makes this harder.

The Trump Taj Mahal systematically failed to file them. Thousands of transactions went unreported. The FinCEN consent order documents the scope of the failure across years of operation.

The Prior Violation

The 2015 fine explicitly noted that the Taj Mahal was being assessed a higher penalty because it had previously been cited for BSA violations. The Trump Plaza had faced prior FinCEN action in 1998. The pattern was not new.

The Ownership Timeline

Trump sold his stake in the casino company in 2009 following the company's fourth bankruptcy. He was not the owner at the time of the 2015 fine. He was the operator during the years the violations accumulated.

Timeline

Sequence of events

  1. Plaza Hotel — prior FinCEN AML fine

    The Trump Plaza Hotel and Casino is assessed an earlier FinCEN fine for Bank Secrecy Act violations. The prior action is cited in the 2015 Taj Mahal penalty.

  2. FinCEN issues $10 million fine — Trump Taj Mahal

    FinCEN issues a $10 million consent order against Trump Taj Mahal LLC for 'willful and repeated' Bank Secrecy Act violations. The fine is FinCEN's largest ever against a casino and reflects the casino's history of prior violations.

  3. Taj Mahal closes permanently

    The Trump Taj Mahal closes after its final bankruptcy filing. The casino had opened in 1990 and had declared bankruptcy multiple times. Its closure ends Atlantic City's casino strip era.

Sources

  1. FinCEN Fines Trump Taj Mahal Casino Resort $10 Million for Anti-Money-Laundering Violations — Financial Crimes Enforcement Network (FinCEN)
  2. Trump Taj Mahal Fined $10 Million for Failing to Report Suspicious Transactions — The New York Times
  3. Donald Trump's casino was a money laundering concern for years — The Washington Post
  4. Trump Taj Mahal fined $10M for money laundering violations — The Associated Press

Verification

Publication provenance

Related records

Updated February 17, 2009 Corruption & Self-Dealing
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Sources
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