Tinian Dynasty casino VIP services manager enters deal with US govt

Tinian Dynasty Hotel & Casino VIP services manager George Que has entered an agreement with the U.S. government in exchange for the dismissal of the criminal charges filed against him.

Assistant U.S. attorney Marivic David and Que, through counsel Robert Torres, filed on Wednesday in the U.S. District Court for the NMI a deferred prosecution agreement.

David and Torres also filed a joint motion for court approval of their deferred prosecution agreement.

Under the agreement, the case against Que will be held in abeyance for 18 months.

The U.S. has agreed that if Que is in compliance with the conditions of the agreement, it will drop the indictment filed against him.

Que was among those charged with engaging in a conspiracy to allow gamblers to conduct transactions involving more than $10,000 without filing the required paperwork with the U.S. government.

The indictment, which was filed in May 2013, also charged TDHC casino manager Tim Blyth and Hong Kong Entertainment (Overseas) Investments Ltd, which owns the Dynasty.

Last February, Blyth also entered the same agreement with the U.S. government in exchange for the dismissal of the charges against him. The federal court approved the deferred prosecution agreement.

With respect to Que’s deal, he acknowledged the indictment charging him with one count of conspiracy to cause a financial institution to fail to file a Currency Transaction Report and nine counts of causing a financial institution to fail to file a CTR.

Que acknowledged responsibility for his conduct and agreed to continue his cooperation with the U.S. government in its investigation and that he will no longer work in any position in a financial institution in the United States in which he would supervise employees responsible for handling currency.

The manager also agreed to pay at least $5,000 for any civil monetary penalty imposed by the U.S. government or its agencies.

The U.S. government agreed that Que may leave the CNMI and reside outside the U.S. during the term of the deferred prosecution (18 months).

According to the statement of facts in the agreement, Que was aware that regulations required Dynasty to file a Currency Transaction Report whenever it engaged in a transaction involving either cash in or cash out of more than $10,000 during a single gaming day.

Before concluding any such transaction, Dynasty was also required to verify and record, among other things, the name and address of the individual presenting a transaction.

During Que’s tenure as VIP services manager between March 1, 2011, and April 24, 2013, Dynasty failed to prepare CTR forms for approximately $27 million in reportable currency transactions required by the Bank Secrecy Act and its regulations.

In addition, Dynasty failed to fully identify and disclose all individuals involved in or actually conducting the transactions and did not include any Social Security numbers or tax ID numbers on the CTR forms.

Furthermore, TDHC failed to file even those CTR forms that were prepared, causing a total of about $90 million in reportable transactions to not be filed.

In May 2012 and September 2012, Que spoke via telephone to an undercover law enforcement agent and assured him that he and his Russian business associate, another undercover agent, could gamble at Dynasty with large amounts of currency and that no paperwork would be filed by the casino to report such transactions, except to the CNMI Customs at the Saipan airport.

Between Feb. 28, 2013, and March 4, 2013, two undercover law enforcement agents posed as casino players at the TDHC and conducted currency transactions totaling $450,130.

Blyth, the casino general manager, and Que met the undercover agents and knew they each conducted several currency transactions that required the preparation and filing of CTRs.

Dynasty failed to develop, implement, and maintain an effective anti-money laundering program, as part of a pattern of illegal activity involving more than $100,000 in a 12-month period.

“As a result, [Dynasty], Blyth, and Que failed to identify and report potential money laundering activity,” according to the deferred prosecution agreement.