| Agreement Information |
| Type of crime: |
Money Laundering |
| Docket text*: |
|
| Agreement text: |
PDF
|
| Disposition type: |
NP
|
| Agreement date (yyyy-mm-dd): |
2021-10-22 |
| Jurisdiction: |
California - Central District
|
| Document source: |
See: https://www.justice.gov/usao-cdca/pr/bicycle-casino-agrees-pay-500000-settlement-and-submit-increased-review-anti-money |
| Fines / Punishment |
| Length of agreement (in months): |
24 |
| Fine amount ($): |
500,000 |
| Restitution amount ($): |
0 |
| Forfeiture/disgorgement amount ($): |
0 |
| Additional regulatory fine amount ($): |
0 |
| Community service / other penalties ($): |
| Total payments ($): |
500,000 |
| Related Cases |
| Parallel regulatory action? |
-
|
| Regulatory fine ($): |
-
|
| Regulatory disgorgement/forfeiture ($): |
-
|
| Total regulatory payment amount ($): |
-
|
| Payments description: |
-
|
| Parallel civil suit? |
-
|
| Civil judgment? |
-
|
| Civil judgment amount: |
-
|
| Monitor |
| Independent monitor required? |
Yes
: Named "Third-Party Reviewer" to "examine the Bicycle’s compliance with the BSA and other applicable anti-money laundering laws and evaluate whether the program is reasonably designed..."
|
| Other officer required? |
Yes
: Follow-up review and reporting requirements regarding compliance and internal controls around anti-money laundering and other applicable laws.
|
| Compliance program required? |
Yes
|
| New position required? |
-
|
| Outside experts required? |
Yes
: Company required to obtain a third-party audit of its Bank Secrecy Act (“BSA”) compliance program
|
| Governance changes required? |
-
|
| Who selects monitor? |
Yes
|
| Length of monitorship (in months): |
24
|
| Monitor name: |
-
|
| Was the monitor a former prosecutor? |
-
|
| Other Agreement Variables |
| Leniency considerations? |
Yes
: cooperation, commitment to enhancing compliance, positive actions.
|
| Accept responsibility? |
Yes
: See Attachment A.
|
| Statement of facts: |
Yes
: Company violated Bank Secrecy Act.
|
| United States Sentencing Guidelines? |
-
|
| Description of pre-agreement compliance |
-
|
| Regulatory compliance required? |
-
|
| Unrelated terms: |
-
|
| Privacy waiver? |
-
|
| Fine calculation included? |
-
|
| Fine description: |
-
|
| Can DOJ unilaterally terminate agreement? |
-
|
| Regulatory agency: |
-
|
| Part of Swiss Bank Program? |
-
|
| Notes: |
-
|
*The docket above is unofficial and may be incomplete or out-of-date. The official docket is available on
PACER (fees may apply).