In the Matter of Artichoke Joe’s, a California Corporation d/b/a Artichoke Joe’s Casino
The Financial Crimes Enforcement Network (FinCEN) has determined that grounds exist to assess a civil money penalty against Artichoke Joe’s, a California corporation d/b/a Artichoke Joe’s Casino (AJC), pursuant to the Bank Secrecy Act (BSA) and regulations issued pursuant to that Act.2
AJC admits to the facts set forth below and that its conduct violated the BSA. AJC consents to the assessment of a civil money penalty and enters into the CONSENT TO THE ASSESSMENT OF CIVIL MONEY PENALTY (CONSENT) with FinCEN. The CONSENT is incorporated into this ASSESSMENT OF CIVIL MONEY PENALTY (ASSESSMENT) by reference.
FinCEN has the authority to investigate and impose civil money penalties on card clubs for violations of the BSA. 3 Rules implementing the BSA state that “[o]verall authority for enforcement and compliance, including coordination and direction of procedures and activities of all other agencies exercising delegated authority under this chapter” has been delegated by the Secretary of the Treasury to FinCEN.4
AJC is a card club located in San Bruno, California and has been in operation since 1916. It contains 38 tables offering card and tile games, including baccarat, blackjack, poker, and Pai Gow. AJC was a “financial institution” and a “card club” within the meaning of the BSA and its implementing regulations during the time relevant to this action.5 The Internal Revenue Service (IRS) examines card clubs for compliance with the BSA under authority delegated by FinCEN.6 IRS conducted an examination of AJC in 2015 that identified significant violations of the BSA.
On May 9, 2011, AJC entered into a stipulated settlement with the California Bureau of Gambling Control. AJC agreed to pay a fine of $550,000, with $275,000 stayed for a two-year period, and agreed to modify its surveillance, work with the city of San Bruno to improve coordination with law enforcement, replace employees at the Pai Gow tables, and provide additional training on loan-sharking, illegal drugs, and compliance with the BSA. 7