Atlantic City Casino Regulatory Violations: Fines, Discrimination Citations, and Anti-Money Laundering Failures
Tier 1Resolved1990-01-01 to 2015-03-06
Factual Summary
Donald Trump's Atlantic City casino operations accumulated a significant record of regulatory violations, fines, and citations from the New Jersey Casino Control Commission and federal regulators over approximately 25 years of operation.
In December 1990, Fred C. Trump, Donald Trump's father, sent a lawyer to Trump Castle Casino Resort to purchase $3.35 million in gambling chips. The chips were never used for gambling. The transaction functioned as an illegal loan to help the casino meet a bond payment. The New Jersey Casino Control Commission determined that the chip purchase constituted an unauthorized financial transaction and fined Trump Castle $65,000. The Commission also charged Trump's operation with violating the Casino Control Act for failing to disclose Fred Trump as a financial backer, imposing an additional $30,000 civil penalty.
In June 1991, the New Jersey Casino Control Commission fined Trump Plaza Hotel and Casino $200,000 for accommodating the discriminatory preferences of Robert LiButti, a high-roller with ties to the Gambino crime family. Between 1986 and 1988, Trump Plaza managers had removed Black and female dealers from LiButti's table at his request. The Commission found that Plaza management had engaged in a pattern of catering to LiButti's racial and gender preferences to retain his gambling business. Trump Plaza appealed the penalty and lost in October 1992.
In 1998, the Financial Crimes Enforcement Network fined the Trump Taj Mahal $477,000 for violations of the Bank Secrecy Act related to anti-money laundering compliance failures. The Taj Mahal had failed to properly file currency transaction reports for large cash transactions.
In 2015, FinCEN imposed a $10 million civil penalty on the Trump Taj Mahal, at the time the largest fine ever levied against a casino for Bank Secrecy Act violations. In the consent order, the casino admitted that it had "willfully violated" the Bank Secrecy Act's reporting and recordkeeping requirements from 2010 through 2012. The violations included failure to implement and maintain an effective anti-money laundering program, failure to report suspicious transactions, failure to properly file currency transaction reports, and failure to maintain required records. Federal investigators had noted that the Taj Mahal was a preferred gambling venue for Russian organized crime figures based in Brooklyn during the 1990s and early 2000s.
The Casino Control Commission documented additional violations across Trump's properties over the years, including issues related to gaming floor management, financial reporting deficiencies, and insufficient internal controls over accounting practices.
Primary Sources
1. New Jersey Casino Control Commission orders regarding Trump Castle chip purchase (1990) and related fines
2. New Jersey Casino Control Commission, Docket No. 91-1060-VC, order regarding Trump Plaza discrimination fine, June 1991
3. FinCEN consent order: Trump Taj Mahal Casino Resort, $10 million penalty, March 6, 2015: https://www.fincen.gov/news/news-releases/fincen-fines-trump-taj-mahal-casino-resort-10-million-significant-and-long
4. FinCEN penalty against Trump Taj Mahal Associates, 1998
Corroborating Sources
1. UPI: "Trump Plaza fined $200,000 for discrimination," June 6, 1991
2. CNN: "Trump's casino was a money laundering concern shortly after it opened," May 22, 2017
3. ProPublica/WNYC: "'Trump, Inc.' Podcast: Money Laundering and the Trump Taj Mahal"
4. Congressional record, House Judiciary Committee, September 29, 2020: "How Donald Trump Bankrupted His Atlantic City Casinos"
Counterarguments and Context
Trump's representatives argued that the Atlantic City casino industry as a whole was subject to extensive regulatory scrutiny and that regulatory citations were common across the industry, not unique to Trump properties. Regarding the LiButti discrimination fine, Trump denied having a personal relationship with LiButti despite photographic and documentary evidence placing them together at events. On the anti-money laundering violations, Trump's team noted that by the time the $10 million FinCEN fine was imposed in 2015, Trump had already gone through corporate restructuring and no longer held a controlling interest in the casino company, which was operating under bankruptcy protection. The casino's legal team characterized the BSA violations as compliance failures at the operational level rather than evidence of intentional facilitation of money laundering. The $10 million FinCEN fine, however, reflected the severity and duration of the violations, and the consent order's acknowledgment that the violations were "willful" undercut the characterization of mere operational lapses.
Author's Note
This entry is classified as Tier 1 because the regulatory violations were adjudicated by the New Jersey Casino Control Commission and FinCEN, the fines were imposed through formal administrative proceedings, and several were upheld on appeal. The discrimination fine and the anti-money laundering penalties are matters of settled regulatory record. The 2015 FinCEN consent order, in which the Trump Taj Mahal admitted to willful BSA violations, represents a particularly strong evidentiary foundation.