New Jersey Casino Regulatory History: Anti-Money Laundering Violations, FinCEN Penalties, and Organized Crime Associations
Tier 3Resolved1982-03-01 to 2015-03-06
Factual Summary
Donald Trump's casino operations in Atlantic City were subject to regulatory oversight by the New Jersey Casino Control Commission and the Division of Gaming Enforcement from the time Trump received his initial casino license in March 1982. Over the following three decades, the regulatory record documented a pattern of anti-money laundering violations, organized crime associations among contractors and patrons, and repeated compliance failures.
In the early 1990s, the Trump Taj Mahal casino violated anti-money laundering rules 106 times in its first year and a half of operation, according to an IRS review documented in a 1998 settlement agreement. In 1998, the Financial Crimes Enforcement Network (FinCEN) assessed a $477,700 civil money penalty against the Taj Mahal for currency transaction reporting violations.
In 2015, FinCEN imposed a $10 million civil penalty against the Trump Taj Mahal for "significant and long standing" willful violations of the Bank Secrecy Act. In the consent order, the casino admitted it had "willfully violated" the Act's reporting and recordkeeping requirements from 2010 through 2012. The violations included failures to implement adequate anti-money laundering program requirements, failures to meet reporting obligations, and failures to maintain required records. FinCEN noted that the casino had "a long history of prior, repeated BSA violations cited by examiners dating back to 2003." In addition to the $10 million penalty, the casino was required to conduct periodic external audits of its anti-money laundering compliance program.
The regulatory record also documented associations between Trump's casino operations and organized crime figures. The real estate parcel that became the Trump Plaza Hotel and Casino was leased through a complex ownership scheme involving Kenny Shapiro, who was identified by the New Jersey State Commission of Investigation as a financier for the Philadelphia mafia syndicate led by Nicodemo "Little Nicky" Scarfo. Circle Industries, a drywall contractor for Trump properties, was implicated in a racketeering scheme between the carpenters' union and the Genovese crime family as part of a group of 20 drywall makers known as "The Club."
Federal investigations revealed that the Trump Taj Mahal was a preferred location for Russian organized crime figures. Danny Sau Keung Leung, an employee of the Taj Mahal from 1990 to 1995, was identified as an associate of the Hong Kong-based 14K Triad crime group.
Despite these issues, the Casino Control Commission approved and renewed Trump's licenses throughout the period of operation.
Primary Sources
1. FinCEN press release: "FinCEN Fines Trump Taj Mahal Casino Resort $10 Million for Significant and Long Standing Anti-Money Laundering Violations," March 6, 2015: https://www.fincen.gov/news/news-releases/fincen-fines-trump-taj-mahal-casino-resort-10-million-significant-and-long
2. FinCEN consent order, Trump Taj Mahal Associates, 2015
3. FinCEN press release: "FinCEN Announces Penalty Against Trump Taj Mahal Associates," 1998: https://www.fincen.gov/news/news-releases/fincen-announces-penalty-against-trump-taj-mahal-associates
4. New Jersey State Commission of Investigation reports on organized crime in Atlantic City casinos
Corroborating Sources
1. CNN: "Trump's casino was a money laundering concern shortly after it opened," May 2017
2. WNYC Studios, Trump Inc. podcast: "Money Laundering and the Trump Taj Mahal"
3. Medium (Peter Grant): "Casinos, Crime, and Junk Bonds: Trump's Rise in Atlantic City"
4. Paste Magazine: "Donald Trump's Casino Was Deficient in Anti-Laundering Protections"
Counterarguments and Context
The Trump Organization has argued that the anti-money laundering violations were operational compliance failures common in the casino industry and did not reflect intentional facilitation of criminal activity. Trump himself was not personally charged with or found liable for the Bank Secrecy Act violations. The $10 million FinCEN penalty was paid by the corporate entity, not by Trump personally. The organized crime associations involved contractors, patrons, and employees rather than direct business partnerships with Trump himself. The Casino Control Commission continued to find Trump fit to hold a license throughout the period, suggesting that the regulatory body did not consider the issues disqualifying.
Author's Note
This entry is classified as Tier 3 because the key facts are documented through official federal regulatory actions, consent orders, and government reports rather than through investigative journalism alone. The FinCEN penalties were adjudicated through consent proceedings in which the casino admitted to willful violations. The organized crime associations are documented in state commission reports and federal investigations. The regulatory record is notable for its duration and the repeated nature of the violations over more than two decades of casino operations.