Earlier this month, an Atlantic City-based casino was fined $10 million for violating the BSA – more specifically, for failing to (i) create and implement an adequate anti-money laundering program; (ii) establish an effective system of internal controls; and (iii) adequately file currency transaction reports or maintain other required records. Many of the violations that occurred in 2010 through 2012 were previously identified by regulators and brought to the attention of the casino. The federal government will not collect the $10 million civil penalty, but will receive an unsecured claim in the casino’s bankruptcy, pending approval from the bankruptcy judge.