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In 2025, the Nevada Gaming Commission (Commission) and the Nevada Gaming Control Board (NGCB) launched one of the most significant enforcement waves in state history, imposing nearly $27 million in fines against three of the Las Vegas Strip's largest operators: Caesars Entertainment, MGM Resorts, and Resorts World Las Vegas. Each case centered on failures to detect and prevent suspicious gambling activity tied to convicted bookmaker Mathew Bowyer, whose presence across multiple properties exposed systemic weaknesses in anti-money laundering (AML) programs. The enforcement actions highlight regulators' growing insistence on robust compliance practices and a culture of vigilance within the gaming industry.
Caesars Entertainment Enforcement Action
The most recent fine, approved on November 20, 2025, ordered Caesars Entertainment to pay $7.8 million following a five-count NGCB complaint. The complaint alleged that Caesars permitted Bowyer to gamble freely across its properties for more than seven years, despite mounting red flags and evidence that other casinos had banned him as early as 2017. Caesars formally designated Bowyer as a "high risk" customer in 2019 yet failed to bar him until January 2024. Regulators described the company's conduct as a systematic negligence, emphasizing that Caesars allowed Bowyer to win and lose millions without verifying his source of funds. The fine was set at roughly three times Bowyer's net losses at Caesars, ensuring the company did not profit from its failures.
The Commission was notably frustrated by ongoing compliance issues across major operators, viewing Bowyer's case as a clear example of broader weaknesses in oversight. The decision to impose penalties, supported by a vote of 4-to-1, underscored both the seriousness of the violations and a strong intent to prevent similar problems going forward.
MGM Resorts Enforcement Action
Earlier in the year, MGM Resorts faced its own enforcement action. In April 2025, the Commission approved an $8.5 million fine against MGM following a 10-count NGCB complaint. The complaint alleged that MGM permitted Bowyer and another illegal bookmaker, Wayne Nix, to gamble at MGM Grand and The Cosmopolitan between 2015 and 2018. Regulators noted that MGM executives had suspicions about Bowyer's source of income as early as 2015, and in 2018 a customer warned MGM that Bowyer was attempting to poach gamblers from its casinos. Despite these warnings, MGM failed to act decisively. The complaint highlighted leadership failures under former MGM executive Scott Sibella, who allowed bookmakers to pay debts in cash and gamble millions without proper AML checks. MGM admitted wrongdoing and pledged reforms, with the Commission approving the fine unanimously.
Resorts World Las Vegas Enforcement Action
Resorts World Las Vegas faced the largest penalty of the three operators. In March 2025, the property agreed to pay $10.5 million following a 12-count NGCB complaint alleging severe AML deficiencies, and the Commission formally approved the fine. Regulators found that Resorts World allowed individuals with ties to illegal bookmaking and gambling-related felony convictions to gamble freely. The fine was the second-largest in Nevada history, behind Wynn Resorts' $20 million penalty in 2019. The case was particularly notable given Resorts World's status as a $4.2 billion property that opened in 2021 with modern infrastructure and the expectation of strong compliance systems. Regulators emphasized that even new properties with advanced technology are not immune from scrutiny if compliance programs fail to meet expectations.
Regulator Expectations
Taken together, the three fines illustrate regulators' frustration with systemic AML failures across operators. Commissioners emphasized that operators must do more than maintain technical compliance programs; they must foster a culture of vigilance that prioritizes integrity over revenue. The Bowyer cases collectively demonstrate that regulators expect operators to proactively monitor high-risk patrons, escalate red flags promptly, and verify sources of funds. The enforcement trend also signals that regulators will not hesitate to impose multimillion-dollar penalties when operators fail to act decisively.
Industry Implications
The implications for the industry are significant. First, the fines underscore the importance of enhanced due diligence for high-risk patrons. Regulators expect operators to verify sources of funds, particularly when patrons engage in high-stakes play or exhibit patterns consistent with suspicious activity. Second, the cases highlight the need for clear escalation protocols. Caesars, MGM, and Resorts World each failed to act on red flags in a timely manner, allowing Bowyer to gamble millions over extended periods. Third, the enforcement actions demonstrate the value of independent audits. Regular reviews can help operators identify gaps in AML programs and remediate deficiencies before they attract regulatory attention.
Beyond technical compliance, the cases emphasize the importance of organizational culture. Regulators criticized operators for prioritizing revenue over compliance, suggesting that leadership must set the tone for vigilance and accountability. MGM's case tied failures to specific executives, underscoring the role of leadership in shaping compliance outcomes. Caesars and Resorts World faced criticism for organizational cultures that allowed high-risk patrons to gamble freely despite clear warning signs.
The reputational damage associated with these fines is also significant. Caesars, MGM, and Resorts World each faced public embarrassment, with executives admitting their programs were "unacceptable." The fines were widely reported in industry and mainstream media, reinforcing the perception that AML failures undermine the integrity of Nevada's gaming industry. For operators, reputational harm can be as damaging as financial penalties, affecting relationships with regulators, investors, and customers.
Looking ahead, operators should expect continued scrutiny from regulators. The Bowyer cases suggest that regulators are focused not only on individual patrons but also on systemic weaknesses in compliance programs. Operators should anticipate more aggressive enforcement, particularly around high-stakes patrons and cash-intensive play. Regulators are likely to demand evidence that operators are proactively monitoring activity, escalating red flags, and verifying sources of funds.
Practical Steps for Operators
To mitigate regulatory risk and strengthen compliance programs, operators should implement enhanced due diligence protocols for high-risk patrons, including mandatory source-of-funds verification. They should establish clear escalation procedures to ensure red flags are acted upon promptly and consistently. Regular independent audits can help identify gaps and remediate deficiencies. Ongoing training for compliance staff and frontline employees is essential to reinforce vigilance and accountability. Finally, operators should benchmark AML practices against industry peers and regulatory expectations to ensure programs remain robust and adaptive.
The Bowyer-related fines against Caesars, MGM, and Resorts World underscore regulators' intolerance for AML failures. Operators must treat compliance as a strategic priority, recognizing that lapses can trigger multimillion-dollar penalties and lasting reputational harm. The enforcement actions highlight regulators' expectation that operators foster a culture of vigilance, where integrity is prioritized over revenue. For the gaming industry, the lesson is clear: AML compliance is not optional, and failure to act decisively on suspicious activity will carry significant consequences.
Ballard Spahr's Gaming Industry Group and Anti-Money Laundering Practice provide comprehensive guidance to public and private sector clients navigating the evolving regulatory landscape. Our team advises on Bank Secrecy Act and anti-money laundering compliance, assists with governmental inquiries, investigations, enforcement proceedings, licensing matters, internal risk assessments, policy development, training programs, transactional due diligence, technology integration for compliance monitoring and reporting, and crisis management in response to active investigations.
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