https://igamingbusiness.com/legal-compliance/compliance-resorts-world-money-laundering-settlement/

For months, a potential settlement between Nevada and Resorts World Las Vegas (RWLV) dominated the conversation among compliance officials at networking events on the conference circuit.

A litany of civil complaints against RWLV and several other Strip properties have given regulators agita, with one Nevada commissioner warning that the financial improprieties would serve as a wakeup call for the industry as a whole.

Given the severity of the allegations, one option for state regulators involved placing RWLV into conservatorship, a strict penalty that would have ranked among the harshest available. Alternatively, a $100 million fine ($£77 million/€89 million) in combination with a license suspension could have been just as punitive, or even worse.

In the end, the Nevada Gaming Commission (NGC) approved a $10.5 million fine against RWLV. It is the second largest fine levied against a casino in state history.

The settlement served as a hot topic at last week’s Indian Gaming Tradeshow & Convention, the nation’s largest tribal gambling conference. A stipulated settlement finalised by the NGC on 27 March resolved a 12-count regulatory complaint centered on the casino’s anti-money laundering deficiencies.

Numerous panels addressed the settlement, as well as the sweeping investigation into the Southern California illegal sports betting market, which occupied a central role in the RWLV case. One panel discussing the casino industry’s evolving anti-money laundering landscape delved into the challenges compliance teams can face when designing a remediation plan following a major settlement.

“Having compliance in place can’t be so detrimental to the business that the business cannot function,” said Anne Layne, senior manager at Grant Thornton, one of the largest US accounting and advisory firms.

No admissions of wrongdoing

Last summer, the Nevada Gaming Control Board issued a multi-count complaint against RWLV, a 117,000-square-foot casino located on the north end of the Las Vegas Strip. Opened in 2021 at a cost of $4.3 billion, the resort is the most expensive property in the history of Sin City. The settlement pertains to criminal charges against two illegal bookmakers, both of whom are awaiting sentencing on federal money laundering charges.

One bookmaker, Matt Bowyer, has garnered headlines for his association with Ippei Mizuhara, the former interpreter for Los Angeles Dodgers star Shohei Ohtani. For a three-year period, Mizuhara placed approximately 19,000 wagers with Bowyer’s illegal sportsbook, amounting to more than $325 million in handle. Bowyer, meanwhile, gambled at RWLV on at least 80 occasions, losing at least $7.9 million, according to a Nevada regulatory complaint.

Mizuhara, who admitted embezzling more than $16 million from Ohtani to feed his gambling habit, received a 57-month prison sentence in February. The former interpreter is scheduled to surrender to federal authorities by 12 May.

Ippei Mizuhara has a little more 'freedom' until he's due to begin his sentencing.https://t.co/HrRPUUBpZD

— Dodger Blue (@DodgerBlue1958) April 10, 2025

Despite several meetings discussing Bowyer’s activities, the casino’s AML committee failed to substantiate that Bowyer’s source of funds matched his volume of play. According to the complaint, RWLV never performed the required Know Your Customer check on the bookmaker. Investigators also probed whether the casino’s sportsbook enlisted illegal bookies as an avenue for laying off excessive risk.

The NGC approved the settlement on a 4-0 vote, with commissioner Abbi Silver recusing herself from the matter. She cited a longstanding relationship with Scott Sibella, a former RWLV president. Sibella was sentenced last May to a year of probation. He later had his Nevada gaming licence revoked for AML violations during his tenure at the MGM Grand. RWLV has not admitted to any wrongdoing in relation to the complaint.

Striking a balance

The tribal conference panel discussing AML issues spent a large portion of the hour-long session on the RWLV matter. In addressing a room full of compliance officials, the panel outlined the remediation strategies available when costs become an issue. As a rule of thumb, compliance teams should focus less on passing an exam when approached by regulators, Layne said. Instead, the teams should focus more on developing a framework that prevents activity that can land their casino in hot water.

One option for regulators centers on stipulations that would require affected casinos to hire an independent AML monitor. The third-party monitors could be utilised to tackle suspicious activity in real time, on a 24/7 basis. From a compliance perspective, the presence of such a monitor would be “fantastic”, Layne suggested. While the remediation appears logical in theory, however, the high cost burdens can make implementation less practical.

Casinos-AML-Regulators. The most recent example of the importance of gaming compliance https://t.co/dOwXh2vnAT

— Karl Sleight (@KarlSleight) March 27, 2025

A stipulation that requires a casino to pay a third-party monitor could cost so much it becomes detrimental, Layne explained. At the same time, regulators are acutely aware of how sanctioned casinos still need to generate revenue during a comprehensive remediation. On a macro level, state bodies are incentivised to assist casinos with their recovery in order to maintain tax proceeds and revenue share from the property, she noted.

“While compliance is important, it is also important to make sure that the businesses can continue — it’s really about striking a balance,” Layne said.

A federal settlement?

Layne was joined on the panel by Sean Topchi, an executive who serves as director of business development at Kinectify. Topchi is intimately familiar with the facts of the RWLV case since he was formerly employed as the Bank Secrecy Act officer for Morongo Casino Resort & Spa, a large tribal casino in Southern California. Topchi was quick to note that a considerable amount of remediation has already been implemented by RWLV, including a new corporate governance structure.

Nevada regulators still have the option of revisiting the settlement if there is criminal or civil action taken on the federal level, Topchi noted. At last month’s hearing, Nevada Commissioner Brian Krolicki indicated that the option represented one of the most integral aspects of negotiations. Topchi believes the federal probe may be “close to the finish line”, resulting in a “decent” chance of a settlement by the Justice Department.

The Nevada Gaming Commission unanimously approved one of the largest penalties in state history over historic AML failures at Resorts World Las Vegas, second only to Wynn’s $20M fine in 2019 https://t.co/Wm0RGIJltJ pic.twitter.com/q4JqWAZDop

— GGB (@GlobalGamingBiz) March 28, 2025

At a separate session in San Diego, federal prosecutor Jeff Mitchell gave a presentation on methods to combat money laundering. Mitchell, an assistant US attorney for the Central District of California, specialises in complex matters related to bank fraud, money laundering, tax offences and Title 31 BSA issues, among others. He is also lead prosecutor in the intertwined Southern California gambling probe.

Mitchell addressed several adjudicated cases involving Mizuhara, Sibella and the MGM Grand, but he did not discuss Bowyer’s ongoing case.

Initially scheduled for last week, Bowyer’s sentencing has been moved to October. Damien Leforbes, another bookmaker who pleaded guilty on money laundering charges, is scheduled to be sentenced in June.

Under the Biden administration, the federal government considered a nine-figure fine against RWLV, multiple sources told iGB. The status of any possible settlement appears to be unclear, due in part to the leadership transition in the Justice Department.