FinCEN Issues Proposed Rule for Suspicious Activity Report Sharing Pilot Program

On Monday of this week, the Financial Crimes Enforcement Network (FinCEN) issued a press release and a Notice of Proposed Rulemaking (NPRM) that proposes and solicits public comment on the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs), in accordance with Section 6212 of the Anti-Money Laundering Act of 2020.

The pilot program would permit a financial institution (including casinos) with a SAR reporting obligation to share SARs and information related to SARs with the institution’s foreign branches, subsidiaries, and affiliates for the purpose of combating illicit finance risks, subject to approval and conditions set by FinCEN. The proposed rule aims to ensure that the sharing of information is limited by the requirements of federal and state law enforcement, takes into account potential concerns of the intelligence community, and is subject to appropriate standards and requirements regarding data security and the confidentiality of personally identifiable information.

“This NPRM builds on the experience that FinCEN has gained in administering existing pilot programs and once finalized, will assist financial institutions in further combating illicit finance risks. We expect that the pilot program will provide valuable feedback to FinCEN as longer-term approaches towards SAR sharing with foreign affiliates are considered,” said FinCEN Acting Director Himamauli Das. “We urge stakeholders to provide input to assist us in developing a program that will help combat illicit finance risks and promote enterprise-wide risk management, while ensuring adequate safeguards are in place to protect SAR confidentiality.”

FinCEN’s previously issued guidance on sharing SARs within a corporate organizational structure stated that financial institutions may share SARs with foreign head offices, controlling companies (whether domestic or foreign), and domestic affiliates. If finalized, the proposed rule would establish a limited-duration pilot program to allow SAR sharing with foreign affiliates, which would also provide FinCEN with valuable feedback about the value of such SAR sharing for participating financial institutions and for FinCEN and law enforcement.

The proposed rule seeks public comment on questions related to the establishment of a SAR sharing pilot program, such as expected costs and benefits, technical challenges, the merits of quarterly reporting, and how to protect SAR confidentiality. Comments can be made by following the link below:

Pilot Program on Sharing of Suspicious Activity Reports and Related Information

Gun Lake Casino President Sal Semola Named Newsmaker of the Year

At its first in-person awards ceremony since early 2020, the Grand Rapids Business Journal named Salvatore (Sal) Semola, President of Gun Lake Casino, the publication’s 2021 Arts/Entertainment Newsmaker of the Year.

In an interview with The Michigan Gaming Newsletter Sal Semola stated “ “I am honored to accept this award on behalf of Gun Lake Casino and the Gun Lake Tribe. The efforts expended by all of our team members and the support of the tribe are the ones who have truly made this possible.”

The award recognizes the substantial accomplishments of Gun Lake Casino throughout 2021. In addition to completing the casino’s $100 million expansion, including new and enhanced entertainment and dining options, Gun Lake became the name-in-title sponsor for Grand Rapids’ 20 Monroe Live, renaming the contemporary concert hall GLC Live at 20 Monroe.

Caesars Windsor Reopening with Safety Protocols on Monday

Caesars Windsor announced that it will reopen on Monday, January 31st, at 50 percent capacity. According to its website, Caesars Windsor is requiring guests to comply with the below safety guidelines to enter the casino:

Any customer wishing to enter the casino must first provide proof of identification and proof of being fully vaccinated with a COVID-19 vaccination approved by Health Canada.
Enhanced vaccine certificate with QR code for Ontario residents will be required to be provided by customers. Digital or printed QR codes will be accepted. Enhanced certificates with QR codes can be downloaded by visiting https://covid-19.ontario.ca/book-vaccine/.
Physician notes for medical exemptions from COVID-19 vaccinations for Ontario residents will no longer be accepted. An enhanced COVID-19 vaccine certificate with QR code will need to be provided if a customer has an eligible medical exemption.
Customers refusing to provide the required proof of vaccination status or proof of medical exemption status at the point of entry to the casino, will not be permitted access to the casino.
Customers are required to wear face coverings at all times except when eating and/or drinking.
Customers will be educated prior to their arrival on these health and safety guidelines and on what to expect at the property during their visit.
Before permitting entry, or as requested by employees, customers will be required to attest to a health assessment and may be asked to briefly lower face coverings for age and identification purposes in compliance with Ontario gaming regulations.
Incident response protocols have been developed to reduce the chance the infection will spread. In the event that there is a potential case of COVID-19 on property, these protocols will be activated to provide the customer with access to medical treatment, thoroughly disinfect exposed areas and provide any required notifications to those who have come in close contact with the customer. Security staff is trained to respond quickly in the event of an incident.
Contact tracing information will be gathered and retained for at least thirty (30) days.

Additional information on the safety protocols, including information on steps being taken by employees and related to the facility can be found at the following link. https://www.caesars.com/caesars-windsor/hotel/health-and-safety

Pokagon Band and Its Four Winds Casinos Contribute $860,000 to the City of South Bend and Local Non-Profits

The Pokagon Band of Potawatomi and its Four Winds Casinos are pleased to announce that they presented checks totaling $860,000 to South Bend Mayor James Mueller and representatives from several area non-profits today at a ceremony at Four Winds South Bend.

“The Pokagon Band is very pleased to be able to make these contributions to the City of South Bend, the Boys & Girls Clubs of St. Joseph County, YWCA of North Central Indiana, the Food Bank of Northern Indiana, Jobs for America’s Graduates Indiana, Beacon Health Foundation, the Bowman Creek Project, South Bend Community School Corporation, and South Bend Venues, Parks & Arts for the renovation of Howard Park,” said Rebecca Richards, Tribal Chairwoman of the Pokagon Band and CEO of the Pokagon Gaming Authority. “Not only is South Bend home to hundreds of our Pokagon Citizens, but also many of our employees that work at Four Winds South Bend. We are very proud to support the city, along with these important organizations that play a vital role to serve the residents of the community and help make South Bend a better place to live.”

“We are grateful for our government-to-government relationship with the Pokagon Band of Potawatomi and their generous contributions to the City of South Bend, which help fund a variety of city services and community development initiatives,” said Mayor James Mueller.

The Pokagon Band voluntarily entered into an agreement with South Bend to make annual payments from revenue from its Class II gaming devices at its Four Winds South Bend casino. The annual payments are in lieu of property tax payments and provide funding for city services and funding for community development initiatives related to the Band’s trust lands in South Bend. One percent of the Class II revenues is paid directly to the city and another one percent is paid to the South Bend Redevelopment Commission to contribute to the improvement of educational opportunities and to address poverty and unemployment in the city. The agreement between South Bend and the Pokagon Band is similar to those in three additional communities where the Pokagon Band’s Four Winds Casinos operate.

In addition to the annual payments to the City of South Bend, the Pokagon Band also proposed to fund a variety of community development projects and causes. Organizations receiving a portion of today’s revenue share are:

The Boys & Girls Clubs of St. Joseph County received $20,000.
The YWCA of North Central Indiana received $25,000.
The Food Bank of Northern Indiana received $20,000.
Jobs for America’s Graduates Indiana received $50,000.
Beacon Health Foundation received $100,000.
The Bowman Creek Project received $100,000.
The South Bend Community School Corporation received $100,0000.
South Bend Venues, Parks & Arts received $445,000.

DraftKings Announces Program to Support State Problem Gambling Councils

Continuing its commitment to responsible gaming, DraftKings announced The State Council Funding Program on January 20, 2022. The Program embodies a multi-year financial commitment to advance responsible gaming by offering to each of the thirty-five state problem gambling councils $15,000 per year for three years, totaling $1.575 million in funding. DraftKings will launch the Program with a three-year trial beginning in January 2022.

“I have seen first-hand how these organizations are a tremendous resource for individuals and families, and serve as a critical stakeholder and partner for gaming operators,” recounted Christine Thurmond, Responsible Gaming Director for DraftKings. “Our hope is that this funding will give councils that extra support needed to fund priority areas, expand services, or hire additional staff.”

DraftKings gives broad deference to state councils to use their funding in ways that improve the operation of responsible gaming programs for individuals and families. Improvements may take the form of enhanced trainings, conferences, helplines, and general capacity upgrades. Additionally, the Program enables state councils to explore expansion opportunities in states that lack a problem gambling council.

Commenting on the significance of DraftKings’ program, Keith Whyte, Executive Director of the National Council on Problem Gambling, acknowledged that, while state councils “provide critical assistance in the community, they don’t always have the resources and funds to take treatment and prevention to the next level. This significant initiative by DraftKings shows their commitment to and knowledge of the importance of the work state councils provide.”