In 2025, anti-money laundering (AML) practices in the Las Vegas Strip’s biggest casinos have faced unprecedented scrutiny. Following three major casinos settling charges with the Nevada Gaming Commission over AML deficiencies this year, the American Gaming Association (AGA) has released an in-depth guide ahead of the Global Gaming Expo (G2E) in Las Vegas. This guide aims to strengthen AML frameworks not only in Las Vegas but across the entire gambling industry.
Representing the $329 billion US casino industry, the AGA sponsors the G2E annually, making it one of the most significant gatherings in the global gambling sector. The newly released 64-page guide serves as a strategic roadmap for commercial sportsbooks, addressing the growing risks of money laundering in the evolving landscape of gaming transactions, particularly through virtual currencies.
The AGA underscores the critical need for casinos to implement effective risk-based programs to prevent illegal financial activities and preserve the industry’s integrity. These programs must align with the legal obligations set forth by the Bank Secrecy Act.
The binary nature of sports bets, as outlined by the AGA, presents unique challenges in AML efforts. Similar to games like baccarat and craps, sports betting enables individuals to place opposite wagers, thus facilitating money laundering. An example is given where a bettor places $100 on both the home and opposing teams, effectively cleaning dirty money with minimal loss, only the vig.
Further complicating matters, risks increase when bets are placed on behalf of unidentified third parties, a tactic known in gambling circles as using a “beard” to conceal the true source of funds. The importance of stringent AML measures is highlighted by several high-profile legal cases. In particular, the convictions of illegal bookmakers in Southern California over the last two years have intensified the focus on sport betting-linked money laundering.
One prominent case saw Matt Bowyer sentenced to nearly a year in federal prison for running one of the largest illegal sports betting operations in the country. Among his clients was Ippei Mizuhara, former interpreter for baseball star Shohei Ohtani, who funneled approximately $325 million through Bowyer. In Las Vegas, Bowyer laundered millions at Resorts World Las Vegas, prompting settlements by MGM Resorts and Wynn Las Vegas with state regulators.
In March, a $10.5 million settlement with Resorts World marked the second-largest in Nevada’s history, with MGM and Wynn facing fines of $5.5 million and $8.5 million, respectively. The enforcement challenges are compounded when dealing with crypto money laundering. Prosecutors are still pursuing cases against Wayne Nix and Damien LeForbes, the latter accused of laundering hefty sums at a casino believed to be Resorts World.
LeForbes’ federal plea agreement reveals detailed interactions with clients wary of law enforcement. He advised a client to disperse a debt payment across multiple addresses, a tactic to evade detection: “I’d send $100K at a time to different addresses. You can create a different address in a wallet every time. Just don’t send [it] to an exchange.”
During a search on December 22, 2023, authorities confiscated two Trezor wallets from LeForbes’ home. In response to these challenges, the AGA recommends converting virtual currency to US dollars prior to use at sportsbooks. This conversion subjects transactions to the same scrutiny as cash activities, including Suspicious Activity Report (SAR) reviews.
The G2E conference will feature several panels dedicated to AML best practices, with compliance officials from MGM, Wynn, and Resorts World scheduled to participate. While these efforts signal progress, some industry insiders question the overall impact. They argue that the complexity and anonymity of virtual currencies inherently complicate enforcement, suggesting more robust international cooperation and technological innovation may be required.
As casinos adopt these guidelines, the broader industry must remain vigilant. Addressing the evolving threats in AML practices requires not only compliance but a proactive stance against illicit activities. The AGA’s guide acts as a critical tool, but continuous adaptation and collaboration across global jurisdictions will ultimately dictate the effectiveness of these strategies in safeguarding the financial sanctity of the gaming industry.
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