In many respects, Las Vegas casino executives believe the culture of compliance across the Strip has improved dramatically following a slew of historic settlements with Nevada gaming regulators.
At last week’s Global Gaming Expo (G2E), a trio of compliance officers made the case for why their casinos are more equipped to thwart pernicious threats of money laundering and other financial crimes. Over the last six months, the casinos have significantly revamped their compliance programmes after multiple illegal bookmakers exploited vulnerabilities in the systems to launder millions of dollars in ill-gotten gains.
In the first half of 2025 alone, the Nevada Gaming Commission reached settlements with three casinos – MGM Resorts, Resorts World Las Vegas and Wynn – to resolve charges of widespread anti-money laundering deficiencies. Since then, the companies have implemented considerable remedial measures such as extensive staff training, enhanced Know Your Customer (KYC) protocols and periodic reviews from regulators.
But one measure is conspicuously absent: adding independent anti-money laundering monitors inside the sanctioned casinos. For now, none of the casinos appear to be champing at the bit to add the proactive measure on their own.
“I hate to say everybody needs a government monitor,” said Omar Khoury, chief global compliance officer at Wynn Resorts. “Nobody wants a government monitor, but we’re doing it on our own.”
Costly measures for a casino to absorb
In May, the Nevada Gaming Commission approved a $5.5 million fine against Wynn Resorts. The settlement paled in comparison to the $8.5 million and $10.5 million fines levied against MGM Resorts and RWLV, respectively. A year ago, Wynn forfeited $130 million in a non-prosecutorial agreement with the US Justice Department to settle charges that it had conspired with numerous unlicensed money transmitting businesses worldwide.
Khoury stated that any determinations of whether to instal an independent monitor should be made on a “case-by-case” basis. In Wynn’s case, he explained that the company is engaging with a third-party auditor on an annual risk-assessment programme. Since the results are reported back to the casino’s compliance committee, Khoury views it as a hybrid approach for mitigating risk.
Barak Cohen, a former prosecutor with the US Department of Justice, agrees with Wynn’s strategy. Now a partner at Washington DC firm Perkins Coie LLP, Cohen said his firm served as an independent monitor in a major case. It does not mean that he is in favour of the measure. In many instances, monitorships are expensive and a proxy for prosecutors, he emphasised.
“If you can do it for yourself without having the government impose monitorship, then that’s fantastic – monitorships suck,” Cohen said bluntly, while drawing laughter from the audience.
Monitorship costs for a large investigation can run up to $5 million annually, according to Cohen. Moreover, such monitors might search feverishly for problems that in some cases do not exist.
It can lead to aggressive tactics from investigators who are figuratively “kicking in doors” in an attempt to find various issues, according to Cohen.
“If a company can avoid a monitorship, they should,” he told iGB.
Comparisons with the banking industry
Others view monitorship as a much-needed layer of protection for casinos under sanction. The topic of monitorship came up at the Indian Gaming Tradeshow & Convention in April. Anne Layne, senior manager at Grant Thornton, described the monitors as a “fantastic” resource for AML teams to detect real-time activity.
Independent monitoring also received support from several panellists on an AML panel at the Canadian Gaming Summit in June. In the banking industry, K&L Gates has described independent testing as one of the five pillars for AML enforcement.
Last October, TD Bank agreed to pay approximately $3 billion in a historic settlement with US authorities. In one instance, a defendant used the bank to launder roughly $470 million in drug proceeds, while bribing bank employees with some $57,000 in gift cards.
The bank’s AML programme also had “significant deficiencies” in monitoring a classification of high-risk customers, a group that includes internet gambling organisations, foreign casinos and virtual currency exchanges, according to the US Treasury Department.
Under the settlement, TD Bank agreed to appoint an independent monitor to review the bank’s AML programme for a period of four years. It marked the first time that the Treasury’s Financial Crime Enforcement Network (FinCEN) imposed an accountability review that tasked an independent monitor with evaluating such a programme.
Asked if the casino industry should adopt the same measures in AML settlements, MGM Resorts Chief Compliance Officer Stephen Martino responded that he is not familiar with the case. Martino said, however, the company feels “very positively” about its culture of compliance in response to the settlements.
Dreitzer on fines
It should be noted that none of the casinos that settled with Nevada in 2025 were accused of laundering proceeds for narcotics traffickers. In 2013, though, Las Vegas Sands forfeited $47.4 million in a settlement with the Justice Department. The settlement relates to a series of suspicious deposits made by Ye Gon, a Mexican entrepreneur with suspected ties to an international cartel.
Of the three Strip casinos ensnared in this year’s investigation, only RWLV has yet to reach a settlement with the federal government. According to Nevada regulators, RWLV failed to substantiate the sources of funds for Matt Bowyer, an illegal bookmaker who accepted $325 million in wagers from the interpreter at the time for baseball star Shohei Ohtani.
Bowyer, who pleaded guilty to laundering millions through Resorts World, began serving a 12-month prison sentence last week. Since his sentencing, Bowyer has gushed that he is the one mostly responsible for the revamped KYC standards across the Strip.
At G2E, one of the world’s largest gambling conferences, some questioned if monetary penalties are enough of a deterrent. Mike Dreitzer, the newly appointed chairman of the Nevada Gaming Control Board, addressed the matter on the opening day of the event.
“Fines make headlines, but it’s more important that licensees are acting in a corrective way,” Dreitzer said. “Certainly, we are not afraid to continue to ramp up enforcement.”
Independent monitoring has been adopted as a remedial tool in the banking industry, a measure casinos hope to avoid.