US govt files 148 more charges vs Tinian Dynasty owner

From just 10 charges, the U.S. government has added 148 more charges against Hong Kong Entertainment (Overseas) Investments, Ltd., which used to own Tinian Dynasty Hotel and Casino.

A superseding indictment filed in federal court on Monday charged Hong Kong Entertainment with one count of conspiracy to cause a financial institution to fail to file a currency transaction report, 155 counts of failure to file currency transaction reports, one count of failure to file a suspicious activity report, and one count of failure to maintain an effective anti-money laundering program.

If found guilty of one or more of the offenses, the U.S. government wants to forfeit the company’s right to all property and money involved in the offense or each transaction that violated the law.

The initial indictment had charged Hong Kong Entertainment and then-VIP services manager George Que and then-casino manager Tim Blyth with only 10 charges.

According to the new indictment, Hong Kong Entertainment allowed gamblers at Tinian Dynasty to conduct transactions involving more than $10,000 without filing currency transaction reports, or CTRs, with the Financial Crimes Enforcement Network, or FinCEN, from September 2009 to April 25, 2013.

Hong Kong Entertainment allegedly did not file any CTRs on such transactions or cause anyone else to do so, even though the casino was aware of the reporting requirement.

The Internal Revenue Service Criminal Investigation initiated an undercover operation at Tinian Dynasty in May 2012 by having two agents pose as Russian gamblers wishing to use large amounts of cash but not wanting to file any reports with the U.S. government about it.

Tinian Dynasty allegedly failed to file about 3,640 CTRs for cash transactions over $10,000 as required by law. The total dollar amount of reportable currency transactions that were not filed is about $1.38 million.

Between Feb. 28, 2013, and April 25, 2013, Tinian Dynasty also allegedly failed to file a Suspicious Activity Report with FinCEN about the undercover transactions, and did so as part of a pattern of activity involving more than $100,000 in a 12-month period.

From September 2009 up to April 24, 2013, Tinian Dynasty allegedly failed to develop, implement, and maintain an effective anti-money laundering compliance program, and did so as part of a pattern of illegal activity involving more than $100,000 in a year.

Que and Blyth had entered into a settlement deal with the U.S. government in exchange for the dismissal of the criminal charges against them.