Trump Taj Mahal: $10 Million FinCEN Penalty for Willful Anti-Money Laundering Violations
Tier 1Resolved1998-01-01 to 2015-03-04
Factual Summary
On January 27, 2015, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, imposed a $10 million civil money penalty against Trump Taj Mahal Associates LLC for willful and repeated violations of the Bank Secrecy Act. At the time, it was the largest BSA penalty ever imposed on a casino.
The company consented to the penalty and admitted its conduct violated the BSA, acknowledging that it acted "with either reckless disregard or willful blindness" to the law's requirements. The violations spanned more than a decade and included four categories of failure: maintaining an effective anti-money laundering program, filing Suspicious Activity Reports, properly filing Currency Transaction Reports for cash transactions exceeding $10,000, and maintaining required records. IRS examinations found the casino failed to file approximately half of the required SARs during the periods under review.
The pattern of violations was not new. In 1998, FinCEN had assessed a $477,700 civil penalty against the same casino for currency transaction reporting violations. IRS examiners cited BSA violations again in 2003. Subsequent examinations in 2010 and 2012 found that many previously identified deficiencies remained uncorrected. FinCEN noted that the casino "had ample notice" of its obligations because the same violations had been documented in multiple prior reviews.
Trump opened the Taj Mahal in 1990 and maintained ownership through multiple bankruptcies. After a 2009 reorganization, his ownership stake was sharply reduced. By the time the penalty was imposed in January 2015, Trump no longer held a controlling interest. The legal entity penalized was the casino operator. The violations documented in the 2015 action occurred from at least 2010 to 2012, when Trump retained a diminished ownership interest, and the pattern originated during his period of full ownership. The U.S. Bankruptcy Court approved the settlement on March 4, 2015.
Primary Sources
1. FinCEN News Release, "FinCEN Fines Trump Taj Mahal Casino Resort $10 Million for Significant and Long Standing Anti-Money Laundering Violations," January 27, 2015: https://www.fincen.gov/news/news-releases/fincen-fines-trump-taj-mahal-casino-resort-10-million-significant-and-long
2. FinCEN Enforcement Action Page: https://www.fincen.gov/news/enforcement-actions/matter-trump-taj-mahal-casino-resort
3. FinCEN Assessment of Civil Money Penalty (PDF, March 2, 2015): https://www.fincen.gov/sites/default/files/shared/20150302%20Assessment%20of%20Civil%20Money%20Penalty%20Trump%20Taj%20Mahal%20(post-approval%20by%20bankruptcy%20court).pdf
Corroborating Sources
1. CNN Politics: "Trump's casino was a money laundering concern shortly after it opened," May 22, 2017
2. ProPublica / Trump Inc. Podcast: "Money Laundering and the Trump Taj Mahal"
3. FCPA Blog: "FinCEN fines Trump Taj Mahal $10 million for AML and reporting offenses," March 9, 2015
Counterarguments and Context
The company did not deny the conduct and consented to the penalty in the settlement agreement. No documented public statement from Trump specifically addressing or contesting the 2015 FinCEN fine has surfaced in primary sources. The structural defense available to Trump was that by January 2015 he was no longer the controlling owner, and the operating entity rather than Trump personally was the penalized party. The violations, however, originated during his period of ownership and persisted across multiple examination cycles spanning more than a decade.
Author's Note
The $10 million penalty was treated as an unsecured claim in the casino's bankruptcy proceeding and paid on a pro-rata basis alongside general unsecured creditors. The 1998 prior penalty of $477,700 for the same category of violations establishes that the pattern predated the violations cited in the 2015 action.