Lessons from Artichoke Joe’s
Artichoke Joe's may be a casino, but it can provide depository institutions with helpful lessons when it comes to BSA/AML. For example, for years the casino operated under a written compliance program that was filled with blank passages or placeholder language. It was lax in conducting independent testing. Hence, in May 2018, it settled with FinCEN for $5 million civil penalty. [8/15/18]


