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Nevada Gaming Commission approves $5.5 million settlement with Wynn Las Vegas over unlicensed money transfers and related failures
Summary
The commission accepted a negotiated stipulation resolving a complaint tied to a federal non-prosecution agreement. Wynn admitted the facts, agreed to a $5.5 million state fine and multiple remedial conditions after federal prosecutors pursued forfeiture tied to unlicensed money-transmitting activity involving third parties and certain employees.
The Nevada Gaming Commission on Thursday approved a stipulated settlement with Wynn Las Vegas LLC that resolves a complaint tied to a federal non-prosecution agreement (NPA). Under the agreement approved by the commission, Wynn admits the facts in the complaint, will pay a $5,500,000 administrative fine to Nevada and must maintain specified enhancements and ongoing reporting tied to its anti-money‑laundering (AML) and third‑party payments controls.
The commission and the Nevada Gaming Control Board (NGCB) presented a complaint alleging that from 2014 onward Wynn, through some employees and certain third‑party independent agents, became involved in the transmission of funds through entities that did not register as money‑transmitting businesses under 18 U.S.C. §1960. The federal NPA — entered between the U.S. Attorney’s Office and Wynn and provided to the commission during the hearing — resolved the federal matter through forfeiture (disgorgement) and standards of remediation; the NPA did not result in criminal conviction for Wynn. The NPA and the board’s complaint detail multiple categories of conduct the government investigated, including international wire transfers handled through third parties, instances described to investigators as proxy or “human‑head” betting, and cases in which certain employees held or moved cash on behalf of patrons without adequate analysis or reporting.
Why it matters: the complaint reflects a set of legacy failures that federal prosecutors addressed under 18 U.S.C. §1960 for unlicensed money transmitting; the state settlement focuses on the adequacy of Wynn’s internal safeguards and on oversight commitments. Wynn’s settlement package combines a monetary penalty with enhanced continuing compliance measures that the NGCB and commissioners described at the hearing as extensive and ongoing.
Key terms of the settlement approved by the commission include: - Admission of the factual allegations in the NGCB complaint (as tied to the federal NPA). - A $5,500,000 administrative fine payable to the State of Nevada. - Maintenance and continued enhancement of Wynn’s core AML program and training (the company must keep employee and independent‑agent training records and supply AML training materials to independent agents). - Independent reviews and audits: Wynn must provide NGCB copies of internal and external audit reports within five business days of completion and deliver specified internal audit reports to the board within defined timeframes. - Continued notice and reporting obligations: Wynn must notify the NGCB and the commission of material amendments to its AML or third‑party‑payment policies and deliver an updated risk assessment and the results of a required “look‑back” review.
What Wynn told the commission: senior Wynn officials framed the settlement as the final step in a long remedial process. Phil Sachtree, chair of Wynn’s board, told the commission he and the board view compliance as central to the company’s business and described steps taken since 2014 to strengthen the tone at the top and broaden training. Omar Khoury, Wynn’s chief global compliance officer, summarized recent upgrades: independent third‑party assessments of the company’s AML program, a consolidated AML compliance manual, expanded in‑person training sessions for high‑risk teams, contractor and independent‑agent contract revisions and new AML technology investments to unify transaction and patron screening workflows.
What the board said: the NGCB explained that the underlying federal matter is different from a classic Bank Secrecy Act enforcement case because federal prosecutors resolved the matter under 18 U.S.C. §1960 focused on unlicensed money transmission by third parties (the statute is uncommon in gaming cases). The board recommended the settlement after weighing the forfeiture amounts in the federal NPA, the remedial steps Wynn implemented, and the company’s cooperation and disclosures during the federal investigation. The NGCB emphasized that the NPA and the complaint do not allege money laundering through Wynn and that the implicated employees and independent agents have been separated from the company.
Dissent and context: one commissioner announced a dissenting view at the meeting and said the state fine was too low given the volume and seriousness of the transactions described in the complaint. Other commissioners said they were persuaded by the company’s remediation and the board’s recommendation; the motion to accept the stipulation carried.
Outlook and follow‑up: the settlement imposes continuing obligations and reporting to the NGCB; the board will monitor Wynn’s compliance with the conditions spelled out in the order. The company must file the updated risk assessment and audit materials the commission and board will receive and review on the NGCB timeline.
Ending: The commission’s approval closes a long federal and state enforcement chapter that began with investigations in 2014 and resulted in a high‑dollar federal forfeiture and a state remediation framework. Officials from both the NGCB and Wynn said they want to move forward with an enhanced partnership focused on monitoring and continuous improvement.
