LOS ANGELES – An investigation of the Normandie Club in Gardena, conducted by the Internal Revenue Service and the California Department of Justice’s Bureau of Gambling Control, has resulted in a million dollar fine and million dollar forfeiture.  On August 30, 2016, the former operator of the Normandie Club was ordered to pay a $1 million criminal fine and to forfeit nearly $1.4 million after pleading guilty to violating the Bank Secrecy Act by failing to report large cash transactions to federal authorities.

As a result of a plea agreement between federal prosecutors and the Normandie Club, the casino pleaded guilty in January to violating anti-money laundering provisions of the Bank Secrecy Act. The partnership specifically pleaded guilty to failing to maintain an effective anti-money laundering program and conspiring to avoid reporting to the government the large cash transactions of some of the casino’s “high-roller” gamblers.    The Normandie Club was also ordered to forfeit $1,383,530, which represents cash transactions in 2013 that were over $10,000 and were not reported properly to federal authorities.

“These investigations can be lengthy and complicated,” said California Statewide Law Enforcement Association (CSLEA) President Alan Barcelona.  “California Department of Justice special agents in the Bureau of Gambling Control do an excellent job investigating this type of activity and working with local and federal law enforcement departments.”

“Our money laundering laws were enacted to prevent criminals from concealing the source of large sums of cash generated by illegal activity,” said United States Attorney Eileen M. Decker. “Casinos and cardrooms such as Normandie are cash-intensive businesses that are particularly attractive for use by criminals seeking to launder their ill-gotten gains, so they must be vigilant in meeting their obligations under those laws.”

In the plea agreement, the Normandie Club admitted that its casino engaged independent gambling “promoters” to locate high-rollers and then steer those gamblers to the casino. As part of the conspiracy, “high-level personnel” at the casino, including the casino’s president and chief operating officer, agreed to avoid reporting to the government the large sums of cash certain high-rollers would bring to the casino. According to the plea agreement, the casino avoided reporting transactions related to the high-rollers by submitting Currency Transaction Reports that named the promoter instead of the gambler, by “structuring” transactions so that they appeared to be less than $10,000, or simply by failing to record large transactions.

During one six-week period in 2013, a single high-roller won more than $1 million from another party at the casino, and the casino conspired to conceal the identity of that high-roller.

“These investigations can be lengthy and complicated,” said California Statewide Law Enforcement Association (CSLEA) President Alan Barcelona.  “California Department of Justice special agents in the Bureau of Gambling Control do an excellent job investigating this type of activity and working with local and federal law enforcement departments.”