Las Vegas casino executives say the Strip’s compliance culture has improved significantly in recent years, following a series of major settlements with Nevada gaming regulators.
At last week’s Global Gaming Expo (G2E), a panel of compliance officers argued that their casinos are now better prepared to combat money laundering and other financial crimes. Over the past six months, several operators have overhauled their compliance programs after investigations revealed that illegal bookmakers had exploited weaknesses in their systems to launder millions of dollars.
In early 2025 alone, the Nevada Gaming Commission finalized settlements with three major operators—MGM Resorts, Resorts World Las Vegas, and Wynn Resorts—over widespread anti-money laundering (AML) failures. Since then, the casinos have rolled out significant reforms, including comprehensive staff training, stronger Know Your Customer (KYC) procedures, and more frequent regulatory reviews.
However, one notable measure remains off the table: the use of independent AML monitors within the affected casinos. So far, none of the operators seem eager to adopt that step voluntarily.
“I hate to say everybody needs a government monitor,” said Omar Khoury, Wynn Resorts’ chief global compliance officer. “Nobody wants a government monitor—but we’re taking the initiative ourselves.”
Costly measures for a casino to absorb
In May, the Nevada Gaming Commission fined Wynn Resorts $5.5 million for anti-money laundering violations—a smaller penalty compared to the $8.5 million and $10.5 million fines issued to MGM Resorts and Resorts World Las Vegas, respectively. Just a year earlier, Wynn had also forfeited $130 million in a non-prosecution agreement with the U.S. Department of Justice to resolve allegations that it conspired with unlicensed money transmitters worldwide.
Wynn’s chief global compliance officer, Omar Khoury, said decisions on whether to appoint an independent compliance monitor should be made on a “case-by-case” basis. He noted that Wynn already works with a third-party auditor to conduct annual risk assessments, with findings reported directly to the company’s compliance committee—a system he described as a “hybrid approach” to managing risk.
Barak Cohen, a former U.S. Department of Justice prosecutor and now a partner at Perkins Coie LLP in Washington, D.C., supported Wynn’s method. Cohen, whose firm has previously served as an independent monitor, cautioned that while monitorships can be effective, they are often costly and burdensome.
“If you can manage compliance internally without a government-imposed monitor, that’s fantastic—because monitorships suck,” Cohen said bluntly, drawing laughter from the audience.
He added that large-scale monitorships can cost companies up to $5 million per year and may result in overly aggressive investigations. In some cases, he said, monitors “kick in doors” searching for problems that might not actually exist.
“If a company can avoid a monitorship, they should,” Cohen told iGB.
Comparisons with the banking industry
Some experts, however, see independent monitorships as an essential safeguard for casinos facing regulatory sanctions. The issue surfaced earlier this year at the Indian Gaming Tradeshow & Convention in April, where Anne Layne, senior manager at Grant Thornton, called independent monitors a “fantastic” tool for AML teams to detect suspicious activity in real time.
The concept also gained traction during an anti-money laundering (AML) panel at the Canadian Gaming Summit in June, where several panellists voiced support for independent oversight. In the banking industry, law firm K&L Gates has even identified independent testing as one of the five core pillars of AML enforcement.
A recent example of this approach occurred last October when TD Bank agreed to pay roughly $3 billion in a landmark settlement with U.S. authorities. According to the U.S. Treasury Department, the bank’s AML programme suffered from “significant deficiencies,” particularly in monitoring high-risk clients such as online gambling operators, foreign casinos, and cryptocurrency exchanges.
One case involved a defendant using TD Bank to launder approximately $470 million in drug proceeds, reportedly bribing bank employees with $57,000 in gift cards.
As part of the settlement, TD Bank consented to appoint an independent monitor to oversee its AML programme for four years—marking the first time the Treasury’s Financial Crimes Enforcement Network (FinCEN) required such a measure as part of an accountability review.
When asked whether similar monitorships should be implemented in casino AML settlements, MGM Resorts Chief Compliance Officer Stephen Martino said he was not familiar with the TD Bank case. However, he emphasized that MGM remains “very positive” about its compliance culture and the progress made following its recent settlements.
Dreitzer on fines
It’s worth noting that none of the casinos that reached settlements with Nevada regulators in 2025 were accused of laundering money linked to drug trafficking. However, a decade earlier in 2013, Las Vegas Sands agreed to forfeit $47.4 million to the U.S. Justice Department after investigators traced a series of suspicious deposits to Zhenli Ye Gon, a Mexican businessman suspected of having ties to an international drug cartel.
Among the three Las Vegas Strip casinos investigated this year, Resorts World Las Vegas (RWLV) remains the only one yet to finalize a federal settlement. According to Nevada regulators, RWLV failed to verify the source of funds used by illegal bookmaker Matt Bowyer, who allegedly accepted $325 million in bets from the interpreter of baseball star Shohei Ohtani.
Bowyer, who pleaded guilty to money laundering through Resorts World, began serving a 12-month prison sentence last week. Since his sentencing, he has claimed partial credit for prompting the widespread overhaul of Know Your Customer (KYC) procedures across the Strip.
At this year’s Global Gaming Expo (G2E), one of the largest gambling industry gatherings in the world, some attendees questioned whether financial penalties alone are enough to deter future violations.
Addressing the issue on the event’s opening day, newly appointed Nevada Gaming Control Board Chairman Mike Dreitzer emphasized that while fines draw public attention, genuine reform is more meaningful.
“Fines make headlines,” Dreitzer said. “But what truly matters is that licensees are taking corrective action. And we’re certainly not afraid to step up enforcement when necessary.”
