The Nevada Gaming Commission (NGC) has approved a $5.5 million fine against Wynn Las Vegas for anti-money laundering (AML)-related violations involving unregistered money transmitting businesses (UMTBs). The decision, though approved by a 4-1 vote, was described by some commissioners as a “body blow” to the casino’s reputation and to the commission itself, underscoring ongoing concerns about compliance across the Las Vegas Strip.

The settlement was approved after a tense 90-minute hearing on Thursday, May 22, 2025. NGC Commissioner George Markantonis, reportedly a former president of Las Vegas Sands, strongly criticised the allegations from a six-count regulatory complaint. As reported by iGaming Times from the hearing, Markantonis characterised them as a “body blow” to the company’s reputation and to the commission itself. He indicated, as reported by iGaming Times, that the NGC felt “tested by critiques of perceived leniency in two other cases this year,” and had a chance to “make amends.”

The complaint stems from a September 2024 non-prosecutorial agreement (NPA) with the Justice Department. Under the NPA, Wynn forfeited $130 million to settle allegations that it conspired with unlicensed money transmitting businesses worldwide to transfer funds for the financial benefit of the casino. This settlement is notably the largest of its kind by a casino with the federal government. Commissioner Rosa Solis-Rainey, a 2019 appointee, cast the sole dissenting vote, explaining her decision, as reported by iGaming Times, by describing the settlement amount as “comparatively low relative to the severity of the allegations.”

Allegations of Unlicensed Money Transmitting Businesses

Specific details of the alleged transactions highlight the nature of the UMTB operations. An individual was reportedly operating, managing, or supervising multiple unlicensed and unregistered money transmitting businesses in the US. According to regulatory and court filings, this individual conducted more than 200 transfers with bank accounts controlled by Wynn Las Vegas or associated entities, conducting transactions on behalf of no fewer than 50 casino patrons, amounting to $17.7 million, as prosecutors allege. The fact pattern of these allegations reportedly comports with charges against Juan Carlos Palermo, an Argentinian national who reached a plea agreement with US federal prosecutors in 2022.

Palermo’s unlicensed money transmitting business reportedly operated for a nine-year period through 2020, transacting with clients in at least 15 countries abroad, including Hong Kong, the United Arab Emirates, and the Cayman Islands. The Nevada Gaming Control Board (NGCB) referenced Palermo, described as an independent agent of Wynn Las Vegas, seven times in its 48-page complaint. Prosecutors stated that Palermo’s business enabled clients to conduct international monetary transfers through a series of underground financial networks while circumventing laws and regulations regarding monetary transfer in the US. An example cited: in March 2018, Palermo transferred $200,000 from a bank in Uruguay to a US account he managed; four years later in federal court in California, he accepted a deferred prosecution agreement. All told, the conspirators reportedly steered no less than $130.1 million in financial transactions through the money transmitting businesses.

Wynn’s Response and Other Noted Failures

In a statement, Wynn Resorts accepted responsibility for the violations but asserted that the improper actions were undertaken by “several rogue employees” and claimed the company had “severed ties” with these employees “years ago” while fully complying with the investigation. Attorneys for Wynn told the commission during Thursday’s hearing that at least six employees implicated in the investigation are no longer with the company.

While Wynn rejected an independent agent’s attempt to transfer funds anonymously through a “furniture company” in June 2014, as it had wired money for many patrons, by July 2014, the same agent, acting again as an unlicensed money transmitting business, reportedly used a different third-party entity to wire funds to the casino, which Wynn accepted. Eric Aldrian, chief litigation counsel for Wynn Resorts, provided some clarity on the transactions at Thursday’s hearing, as reported by iGaming Times, stating that at the time, Wynn policy allowed independent agents to pay off outstanding markers on behalf of their patrons, a practice also permissible under state law. He asserted, as reported by iGaming Times, that the 200 transactions were “absolutely seen to us, they were visible and they did not skirt our AML programme.” However, by 2015, Wynn blacklisted two entities utilised by the independent agent. Nevertheless, the agent reportedly continued to conduct business with the casino through a Bank of America account in Florida until April 2021, when the company learned that he charged a 6% commission to patrons, a practice that transitioned him from an independent agent “into the realm” of being an unlicensed money service business. Commissioner Solis-Rainey reportedly criticised Wynn staff for their failure to detect the series of suspicious transactions and the company’s decision to continue business with the agent for six additional years after blacklisting the two entities.

The complaint also detailed other instances of alleged failure to identify suspicious activity: in 2018, Wynn Las Vegas allegedly facilitated $1.4 million in transactions for a former gambling representative publicly linked to proxy gambling. A year earlier, US authorities denied this individual entry into the country due to suspected links to a transnational criminal organisation; despite this awareness, Wynn reportedly never filed a retroactive Suspicious Activity Report. In another instance, Wynn Las Vegas allegedly allowed international monetary transactions of millions of dollars from an individual who spent at least six years in a Chinese prison in connection with unauthorised financial transfers.

The complaint also detailed specific schemes, such as a “flying money” plot, where a money processor (UMTB) was introduced to a Wynn international patron who could not readily access cash in the US, with the processor collecting cash from third parties and delivering it to the patron, often facilitated by the patron’s host. Another violation involved “human hat,” or “human head,” gambling, where a gambler serves as a proxy for an individual prohibited from gambling by the casino, with banned individuals sometimes standing mere feet away, giving instructions without physically handling chips. Commissioner Solis-Rainey reportedly criticised Wynn for not spotting instances of proxy betting on the casino floor.

Broader Industry Enforcement and Ongoing Scrutiny

The hearing on Thursday marked the third time the NGC has convened in recent weeks to discuss a stipulated settlement involving a major Strip property. In March, the NGC approved a $10.5 million fine against Resorts World Las Vegas (RWLV) for AML deficiencies, a case involving allegations against Matt Bowyer, the bookmaker for Ippei Mizuhara (former interpreter for Shohei Ohtani), who reportedly wagered over $325 million with Bowyer’s ring, incurring net losses of $40.2 million. Weeks later, the NGC approved a settlement with MGM Resorts, which accepted an $8.5 million fine. In the MGM case, Bowyer allegedly gambled at MGM over 300 times despite casino officials knowing his occupation as an illegal bookmaker. Notably, MGM expressed contrition and accepted full responsibility for its infractions, unlike RWLV.

Attorneys for Wynn Resorts argued that the facts of their case differed considerably from the two preceding ones. Erica Okerberg, outside counsel for Wynn, stated that their settlement with the Justice Department pertains to violations of Title 18, United States Code, Section 1960, on unlicensed money transmitting businesses, and was not a Bank Secrecy Act (BSA) case, nor were regulators accusing Wynn of transacting with illegal bookmakers. A Nevada deputy attorney general, Nona Lawrence, stated that there were no allegations that any individuals laundered money through Wynn Las Vegas, clarifying that money transmitting businesses, like Western Union, can operate legally if they abide by state and federal laws, including the BSA. Wynn outlined a host of remediation plans to mitigate future risks.

The sweeping investigation into alleged illicit activities is by no means complete. Three bookmakers (Wayne Nix, Damien LeForbes, and Matt Bowyer) still await sentencing. The NGC also delayed action against Nicole Bowyer, Matt Bowyer’s wife, who regulators accused of receiving commissions on her husband’s play as an independent agent of RWLV. In a separate matter, the NGC also granted a temporary license on Thursday to Maurice Wooden, president of the Fontainebleau Las Vegas. At the hearing, the NGC reportedly asked Wooden about his knowledge of a potential AML investigation against Fontainebleau regarding credit transactions involving at least five customers, with NGCB Chairman Kirk Hendrick contending that related materials should have been marked confidential. Wooden stated, as reported by iGaming Times, that AML is “one of the most important topics… we discuss in our leadership meetings.”

While Commissioner Markantonis was reportedly the most animated of the commissioners on Thursday, other commissioners, including Abbi Silver and Brian Krolicki, reportedly hinted that the fine may have been too low. Markantonis expressed concern, as reported by iGaming Times, that the NGC might be perceived as being too soft against the largest casinos on the Strip, referring to critiques that the “big boys” may only receive “a “slap” on the wrist for major infractions. He reportedly warned, as covered by iGaming Times, that “We are not taking prisoners anymore, enough is enough,” and that “The BS is over, it doesn’t matter how fancy your title is.”

In conclusion, the Nevada Gaming Commission’s approval of the $5.5 million fine against Wynn Las Vegas, addressing AML-related violations linked to unregistered money transmitting businesses, marks a significant, albeit controversial, step in a broader regulatory crackdown on financial non-compliance within the Las Vegas Strip’s casino industry. Amidst ongoing investigations and other recent fines against major operators, officials are stressing intensified enforcement and accountability, aiming to ensure robust compliance with financial crime prevention standards.