Las Vegas has once again captured headlines as Wynn Las Vegas agrees to a $5.5 million anti-money laundering penalty. This latest regulatory action, the third of its kind on the Strip in 2025, underlines growing scrutiny on casino operators by the Nevada Gaming Control Board, federal authorities and international watchdogs. Examination of past settlements, legal frameworks and emerging compliance trends sheds light on what led to this landmark decision—and how the industry is gearing up to prevent similar lapses.

Wynn AML fine: Background and Context

Wynn Las Vegas resolved a six-count complaint from the Nevada Gaming Control Board (NGCB) on May 16, 2025, consenting to a $5.5 million penalty for violations involving unlicensed international money transmissions, proxy betting schemes and failures in its internal Anti-Money Laundering Compliance Program. This settlement follows September 2024’s non-prosecution agreement (NPA) with the U.S. Department of Justice—Southern District of California, in which Wynn forfeited over $130 million under the Bank Secrecy Act (31 U.S.C. § 5311 et seq.) for similar conduct. That forfeiture was described by federal prosecutors as “believed to be the largest forfeiture by a casino based on admissions of criminal wrongdoing.”

Mounting investigations unearthed two proxy betting tactics: “human heads,” where third-party bettors placed wagers on behalf of undisclosed high-rollers avoiding AML checks; and “flying money,” unregistered transmitters delivering cash in exchange for currency equivalents plus fees. Funds were routed through offshore agents and third-party accounts into a California-based Wynn-controlled account, then funneled back through the resort’s cage operations—bypassing federal Currency Transaction Reports and Suspicious Activity Reports requirements.

Details of the NGCB Complaint

The NGCB’s complaint cites six counts of conduct dating back to at least 2014, alleging systemic failures to monitor and report suspect transactions under Nevada Revised Statutes Chapter 463 and the Federal Bank Secrecy Act. Key allegations include:

• Unlicensed money transmitting businesses Performing international transfers without state authorization
• Facilitating international monetary transactions Allowing patrons to remit funds via China UnionPay and other systems contrary to U.S. and foreign banking laws
• Proxy betting Enabling “human heads” to wager for undisclosed parties
• Failure to file CTRs and SARs Neglecting mandatory filings for cash transactions over $10,000 and suspicious activities

While the NGCB recommended a $5.5 million fine, the final decision rests with the Nevada Gaming Commission on May 22, 2025. Past precedent shows swift approval: the Commission rubber-stamped similar fines against Resorts World Las Vegas ($10.5 million) and MGM Resorts International ($8.5 million) without amendments earlier this year.

Comparisons with Other Las Vegas Operators

Resorts World Las Vegas and MGM Resorts faced related penalties in March and April 2025. All three inquiries originated from federal referrals, highlighting the Department of Justice’s role in spearheading money laundering probes within gaming. Key contrasts include:

• Resorts World Las Vegas Fined $10.5 million for wagers placed by illegal bookmakers in 2024
• MGM Resorts International Agreed to $8.5 million for parallel bookmaker schemes involving wire transfers and cash settlements
• Wynn Las Vegas Distinct in its longevity—violations traced over a decade—and its massive prior forfeiture under the NPA

International parallels emerge with Australia’s Crown Resorts and Star Entertainment Group, each sanctioned for illicit transfers via China UnionPay cards. Combined exposures exceeded AU$1 billion, prompting sweeping reforms and executive shake-ups.

Regulatory Environment and Implications

Heightened enforcement reflects a global tightening of AML standards within gaming. Key regulatory drivers include:

• Bank Secrecy Act (31 U.S.C. § 5311 et seq.) Mandates financial institutions—and by extension, casinos—to file CTRs for transactions over $10,000 and SARs for suspect activities
• Nevada Revised Statutes Chapter 463 Implements state-level AML obligations, requiring periodic independent assessments and robust training
• Financial Action Task Force (FATF) Recommendations Influencing U.S. agencies to adopt stricter guidelines on virtual assets and cross-border flows

Wynn Resorts’ commitment to overhaul its compliance framework includes enhanced independent audits, expanded training modules and stricter vetting of third-party agents. “We are pleased that we have resolved this matter with the Nevada Gaming Control Board, which is the same matter Wynn Las Vegas resolved with the U.S. Attorney’s office in September 2024,” Wynn Resorts stated. “Wynn Resorts is committed to acting with the highest integrity and in full compliance with all laws and regulations governing our industry. The improper actions that are the subject of the settlement, which violated Wynn’s own compliance policies and procedures, were undertaken by individuals with whom we severed ties years ago. We accept responsibility for those actions and are now glad the matter will soon be fully resolved.”

Leadership turnover at the NGCB adds another layer: Chairman Kirk Hendrick stepping down June 22, succeeded by former Gaming Arts CEO Mike Dreitzer, marks the board’s fifth leader since 2019. Stability in oversight could drive swifter enforcement—or, critics argue, entrench leniency as major operators navigate negotiated settlements.

Conclusion

Wynn’s $5.5 million AML fine epitomizes sweeping changes in gaming regulation, underscoring the need for ironclad compliance programs under the watchful eyes of both the Nevada Gaming Control Board and federal prosecutors. As operators bolster internal controls and the Commission weighs final approval, the broader lesson is clear: casinos must treat AML obligations with the same rigor as their high-stakes clientele pursue jackpots—lest they risk far more than financial losses.

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Related Links

• Nevada Gaming Control Board News Release
• U.S. Department of Justice NPA with Wynn Resort (Sept. 2024)
• Bank Secrecy Act Overview (31 U.S.C. § 5311 et seq.)
• Nevada Revised Statutes Chapter 463
• Financial Action Task Force Recommendations

Other FinCrime Central News About Vegas Casinos Being Fined One After the Other

• MGM Resorts Hit With $8.5 Million Fine in Major Money Laundering Case
• Resorts World Las Vegas Faces $10.5M Fine for Major AML Failures

Source: IGB, by Jess Marquez

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