Las Vegas's major casinos, after reaching a historic settlement with the Nevada Gaming Control Board, claim to have significantly improved compliance culture, yet still generally resist the introduction of independent anti-money laundering monitoring agencies. In the first half of 2025, MGM Resorts, Wynn Resorts, and Resorts World Las Vegas (RWLV) were fined $8.5 million, $5.5 million, and $10.5 million respectively for anti-money laundering vulnerabilities. Although the casinos have implemented enhanced training, improved KYC protocols, and accepted regular reviews as remedial measures, they all avoid adopting the independent monitoring model common in the banking industry. Wynn's Chief Compliance Officer Omar Khoury and former prosecutors and other industry experts believe that independent monitoring is costly and seems like a "government agent," supporting corporate self-compliance. Regulatory authorities emphasize that besides fines, they are more concerned about the effectiveness of corrective measures, and federal cases show that independent monitoring has been widely applied in anti-money laundering practices in the banking industry.
Regulatory Background and Settlement Situation
In the first half of 2025, the Nevada Gaming Commission reached a settlement with three major casinos to address allegations of anti-money laundering vulnerabilities. MGM Resorts was fined $8.5 million, Wynn Resorts $5.5 million, and Resorts World Las Vegas (RWLV) $10.5 million.
These settlements stemmed from the casinos' failure to effectively prevent money laundering risks, as several illegal gambling companies exploited system vulnerabilities to launder millions of dollars.
Compliance Improvement Measures
The involved casinos have implemented various remedial measures to strengthen compliance construction, including extensive employee training, strengthening the "Know Your Customer" (KYC) protocols, and accepting regular reviews by regulatory authorities.
Casino executives at the G2E expo stated that these improvements enable casinos to better resist money laundering and other financial crime threats, significantly enhancing compliance culture.
Controversy Over Independent Monitoring
Despite strengthened compliance measures, casinos generally avoid adopting the common banking industry practice of independent anti-money laundering monitoring agencies. Wynn Resorts' Chief Global Compliance Officer Omar Khoury stated, "No one wants government oversight," and believes that the need for independent monitoring should be evaluated on a case-by-case basis.
Wynn is cooperating with a third-party auditing firm for annual risk assessments and reporting the results to the compliance committee, adopting a hybrid approach to reduce risks.
Industry Expert Views
Former U.S. Department of Justice prosecutor Barak Cohen agrees with the casino's self-compliance strategy, noting that independent monitoring annual costs could be as high as $5 million, and monitoring personnel might be overly aggressive in seeking problems.
Cohen bluntly stated: "Supervision is terrible," and if companies can comply effectively on their own, they should avoid mandatory supervision, a view that resonates within the industry.
Banking Industry Practices Comparison
Independent monitoring is considered a crucial pillar of anti-money laundering enforcement in the banking industry. TD Bank reached a historic settlement in a money laundering case with U.S. authorities, paying $3 billion and appointing an independent monitor to review its anti-money laundering plan for four years.
The U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) commissioned an independent monitor for the first time to assess a bank's anti-money laundering plan, demonstrating the importance of this measure in the financial industry.
Case Analysis and Industry Impact
RWLV has not yet reached a settlement with the federal government, being accused of failing to verify the source of funds of illegal gambling operator Matt Bowyer. Bowyer laundered millions of dollars through the casino and has begun serving a 12-month sentence.
This case has become a major driver for revising KYC standards, showing the actual impact of compliance failures on the industry.
Regulatory Authority Stance
Mike Dreitzer, the new chairman of the Nevada Gaming Control Board, emphasizes that although fines make headlines, it is more important that licensees take concrete corrective measures. The regulatory authority focuses on the effectiveness of corrective measures rather than just the amount of penalties.
Dreitzer states that the regulatory authority is not afraid to continue to increase enforcement efforts to ensure the industry's compliance level is raised.
Corporate Compliance Strategy
Casinos tend to adopt a mixed model of internal compliance combined with third-party audits, avoiding full external monitoring. Khoury believes that the annual risk assessment reported to the compliance committee is an effective way to manage risks.
Corporate strategies focus on building self-compliance capabilities, reducing reliance on external mandatory supervision.
Cost and Benefit Considerations
Independent monitoring is considered costly, with annual expenses possibly reaching millions of dollars. Experts point out that monitoring personnel might be overly aggressive in seeking problems, leading to unnecessary investigations and costs.
Cost-benefit analysis has become a major consideration factor for casinos refusing independent monitoring, with businesses preferring to invest resources in self-compliance construction.
Future Compliance Trends
The industry may continue to strengthen self-compliance construction while accepting regular third-party audits. Regulatory authorities are expected to focus on the effectiveness of corrective measures, possibly increasing the frequency and depth of reviews.
Compliance culture construction and technological applications will become a focus to adapt to increasingly complex money laundering threats.
International Practice Reference
International gambling markets such as Canada and India are also beginning to discuss independent monitoring systems. Experts from Deloitte believe that monitoring systems are an "excellent" resource for detecting real-time activities.
International practices provide references for Las Vegas casinos, but localized applications still need to consider the characteristics of the U.S. regulatory environment.
Federal and State Regulatory Coordination
Casinos need to address both state and federal regulatory requirements. Last year, Wynn reached a non-prosecution agreement with the U.S. Department of Justice, with $130 million confiscated, showing that the federal level is also strengthening enforcement.
The coordination and cooperation of regulatory authorities at all levels will have a significant impact on casino compliance practices.
