Despite concerns over the casino's past involvement with unregistered money transmitting operations, the NGC approved the settlement in a 4-1 vote.
Following three intense hearings on anti-money laundering practices across the Las Vegas Strip, some members of the Nevada Gaming Commission (NGC) have grown increasingly frustrated with ongoing noncompliance at some of the world’s largest casino operators.
During Thursday’s hearing involving senior executives from Wynn Las Vegas, NGC Commissioner George Markantonis expressed strong disappointment. Referring to the allegations in the six-count regulatory complaint, he described them as a “body blow” to the company’s reputation. Markantonis, a former president of Las Vegas Sands, went further—calling the violations a blow to the commission itself.
Amid criticism that the NGC had shown leniency in two earlier cases this year, Markantonis and the commission faced a critical opportunity to reaffirm their stance on regulatory enforcement.
Roughly 29 minutes later, Commissioner George Markantonis made his decision quickly. Despite being a newcomer to the Nevada Gaming Commission (NGC), he joined three fellow commissioners in approving a settlement with Wynn. Following a tense 90-minute hearing, the NGC voted 4-1 to approve the Nevada Gaming Control Board’s (NGCB) proposed $5.5 million settlement with the casino operator.
The complaint originates from a non-prosecution agreement (NPA) reached in September 2024 with the U.S. Department of Justice. As part of the agreement, Wynn forfeited $130 million to resolve allegations that it had conspired with unlicensed money transmitting businesses around the world to move funds for the casino’s financial benefit. The deal marks the largest such federal settlement ever reached by a casino.
Only one commissioner, Rosa Solis-Rainey—appointed in 2019—voted against the agreement. In her explanation, Solis-Rainey argued that the settlement amount was too low given the seriousness of the allegations.
Millions in transactions
Commissioner Rosa Solis-Rainey highlighted the role of an individual who allegedly operated, managed, or oversaw multiple unlicensed and unregistered money transmitting businesses within the United States. According to regulatory and court records, this person facilitated over 200 transactions using bank accounts linked to Wynn Las Vegas or its affiliates. Prosecutors claim the individual moved funds on behalf of at least 50 casino patrons, totaling approximately $17.7 million.
While the individual’s name was not mentioned during Thursday’s hearing, the details align with charges previously filed against Juan Carlos Palermo, an Argentinian national who reached a plea agreement with federal prosecutors in 2022.
Between 2011 and 2020, Palermo and his unauthorized money transmitting network operated with clients in at least 15 foreign jurisdictions, including Hong Kong, the Cayman Islands, and the United Arab Emirates. Cited seven times in the 48-page complaint from the Nevada Gaming Control Board (NGCB), Palermo was identified as an independent agent of Wynn Las Vegas.
According to prosecutors, Palermo’s business allowed clients to make international financial transfers through underground channels, bypassing U.S. laws and regulations governing money movement.
In one instance, in March 2018, Palermo transferred $200,000 from a Uruguayan bank to a U.S. account he controlled. In 2022, he entered into a deferred prosecution agreement with federal authorities in California.
In total, court documents state that Palermo and his co-conspirators conducted more than $130.1 million in financial transactions through these unlicensed money transmitting operations.
Blacklisted entities
In a public statement, Wynn Resorts accepted responsibility for the violations but maintained that the misconduct was carried out by a group of rogue employees. The company stated that it had severed ties with those individuals years ago and has cooperated fully with the investigation. During Thursday’s hearing, Wynn’s attorneys informed the Nevada Gaming Commission that at least six employees involved in the case are no longer employed by the company.
According to court records, on June 24, 2014, Wynn Las Vegas declined a transaction initiated by an independent agent who attempted to anonymously transfer funds through a third-party entity. The transfer was reportedly rejected because the funds came from a "furniture company" that had previously wired money on behalf of 35 different Wynn patrons.
However, just days later on July 4, the same independent agent—acting as an unlicensed money transmitter—used a different third-party entity to send funds to Wynn. This time, the casino accepted the transfer.
Eric Aldrian, Wynn Resorts’ chief litigation counsel, addressed the transactions during Thursday’s hearing. He explained that, at the time, company policy allowed independent agents to pay off outstanding gambling markers on behalf of patrons, a practice also permitted under Nevada law.
“These 200 transactions were completely visible to us. They did not bypass our anti-money laundering program,” Aldrian told the commission.
