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From September 2014 through February 2019, the anti-money laundering program at Lake Elsinore Hotel and Casino, a now-shuttered, 22-table card club between Los Angeles and San Diego, existed only on paper, if at all. A risk assessment Lake Elsinore completed in or around 2018 does not mention backline betting, pooled banking or any other arrangement that specifically threatens card clubs, and instead inexplicably points out that the club does not engage in asset management, trade finance, correspondent services and other activities that most would associate with banks. The assessment further notes "without explanation" that Lake Elsinore at the time did...