Nevada regulators approve $7.88 million settlement with Caesars over AML failures

The Nevada Gaming Commission on Nov. 20 approved a settlement with Caesars Entertainment that resolves a five‑count complaint alleging persistent failures to verify the source of funds of a high‑volume patron and to follow anti‑money‑laundering (AML) procedures.

Under the stipulation endorsed by the Gaming Control Board and the commission, Caesars agreed to pay a $7,880,000 civil fine and to adopt a series of compliance measures including an annual review of its AML program, enhanced in‑person AML/BSA training for designated staff, participation in FinCEN’s information‑sharing program, designation of a primary AML officer who must apply for licensing, and retention of an independent AML expert within two years to audit compliance.

Mike Soms, a deputy attorney general presenting the board’s case, said the board found repeated missed opportunities over a seven‑year period to substantiate the source of funds of the patron identified in the investigation. "The complaints reflect serious failures on the part of respondents that warrant an appropriate sanction," Soms said, summarizing the board’s recommendation and the scope of remediation required by the stipulation.

Caesars’ senior executives acknowledged the shortcomings and described steps already taken. "The way our AML program operated in this instance was unacceptable," Gary Carano, executive chairman of Caesars Entertainment, told commissioners. "On behalf of Caesars ... I sincerely apologize for our role in the Boyer incident and the impact it had on the gaming industry in the state of Nevada."

Tom Reeg, Caesars’ CEO, said the company has increased AML staffing and spending and elevated oversight. "We didn't catch Boyer, and we should have. Full stop," Reeg said. Chief legal officer Ed Quatman described elevated AML oversight and third‑party reviews the company has begun, and said senior management would participate directly in compliance improvements.

Commissioners pressed Caesars on timing and depth of reforms and on personnel changes. The Gaming Control Board explained that the $7,880,000 figure was calculated to be approximately treble the $2.6 million Caesars won from the patron over the period in question, a multiplier intended to deter recurrence and avoid any net benefit to the licensee.

Several commissioners said they found the package of fines and conditions appropriate to the facts and precedent; one commissioner registered objection before the vote but the motion to approve the stipulation passed on recorded roll call with all commissioners voting aye.

The settlement requires Caesars to maintain minimum AML staffing and to run enhanced source‑of‑funds checks for high‑risk patrons, among other conditions. It also restricts marketing personnel from certain property‑level AML meetings unless authorized by the chief legal officer. The board reserved the right to file additional complaints if federal authorities raise related matters not included in the stipulation.

The commission's action closes the administrative matter before the state regulator; Caesars said it will continue to cooperate with federal authorities as appropriate and implement the compliance measures covered by the stipulation.