In 2025, Las Vegas casinos have made concerted efforts to overhaul their compliance culture following multiple historic settlements with Nevada gaming regulators. At the recent Global Gaming Expo (G2E), compliance officers from several leading casinos asserted their improved readiness to tackle money laundering and other financial crimes. This comes in the wake of revelations that illegal bookmakers had previously exploited weaknesses within casino systems to launder millions.
Earlier this year, the Nevada Gaming Commission reached settlements with major players on the Strip—MGM Resorts, Resorts World Las Vegas, and Wynn Resorts—addressing their shortcomings in anti-money laundering (AML) practices. Acknowledging these deficiencies, the casinos embarked on significant reforms, including comprehensive staff training, strengthened Know Your Customer (KYC) protocols, and ongoing regulator reviews.
Notably absent from these reforms, however, is the adoption of independent AML monitors within these casinos. Despite the pressure, none of the casinos have opted to implement this measure voluntarily. Wynn Resorts’ Chief Global Compliance Officer, Omar Khoury, expressed a common sentiment: while nobody desires a government-imposed monitor, they are committed to improving compliance independently.
In the realm of financial penalties, May saw Wynn Resorts facing a $5.5 million fine from the Nevada Gaming Commission. This fine was relatively modest compared to the $8.5 million and $10.5 million fines imposed on MGM Resorts and Resorts World Las Vegas, respectively. Just a year prior, Wynn had agreed to forfeit $130 million to the US Justice Department in a non-prosecutorial agreement over allegations of conspiring with unlicensed money transmitters globally.
Khoury emphasized that decisions on installing independent monitors should be evaluated on a “case-by-case” basis. He pointed out that Wynn’s approach involves engaging with a third-party auditor for an annual risk assessment, which provides a balanced strategy to mitigate risks effectively.
Barak Cohen, a former US Department of Justice prosecutor and now a partner at Perkins Coie LLP, lent support to Wynn’s approach. Although his firm has served as an independent monitor in a major case, Cohen noted the financial and operational burdens such monitors impose. The costs of such oversight can reach up to $5 million annually and might lead to intrusive investigations. Cohen candidly remarked that if companies can manage without imposed monitorships, they should aim to do so, as the alternative can be unnecessarily cumbersome.
Conversely, others in the industry advocate for independent monitoring as a critical safeguard for sanctioned casinos. At the Indian Gaming Tradeshow & Convention in April, Anne Layne from Grant Thornton described these monitors as invaluable for AML teams needing real-time activity detection. Similarly, a panel at the Canadian Gaming Summit in June highlighted the banking industry’s reliance on independent testing as one of the pillars of AML enforcement, which could serve as a model for casinos.
In a notable banking industry example, TD Bank agreed to a $3 billion settlement with US authorities after failing to prevent the laundering of $470 million in drug proceeds. The bank’s deficient AML program led to the appointment of an independent monitor, the first instance of such a requirement by the Treasury’s Financial Crime Enforcement Network.
When asked about adopting similar measures for casinos, Stephen Martino, Chief Compliance Officer at MGM Resorts, stated a lack of awareness regarding the banking case but maintained confidence in their revamped compliance culture.
Regarding past settlements, none of the 2025 Nevada casino penalties were related to drug trafficking. However, historical cases like the $47.4 million settlement by Las Vegas Sands in 2013 highlight the ongoing challenges in the industry. The case involved suspicious deposits linked to a Mexican entrepreneur with alleged cartel ties.
Of the casinos involved in this year’s investigation, only Resorts World Las Vegas has yet to reach a federal settlement. Nevada regulators have flagged the casino for failing to verify the source of funds associated with illegal bookmaker Matt Bowyer, who took $325 million in wagers illicitly. Recently convicted of money laundering, Bowyer is now serving a 12-month sentence and claims responsibility for driving KYC improvements across the Strip.
At the G2E, some questioned whether fines alone are adequate deterrents for non-compliance. Mike Dreitzer, the newly appointed chairman of the Nevada Gaming Control Board, addressed the audience, emphasizing that while fines attract attention, the priority remains on encouraging licensees to adopt corrective measures. He assured the industry that enforcement efforts will continue to intensify if necessary.
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