Nevada Strengthens Casino AML Rules, NGCB Suggests Additional Measures

Earlier this week, the Nevada Gaming Commission (NGC) adopted new regulations aimed at boosting anti-money laundering (AML) measures. However, Nevada Gaming Control Board (NGCB), (not to be confused with the NGC, although both organizations work closely together) member George Assad wants to create a program that would encourage whistleblowers to report suspicious activity.

Nevada Gaming Commission Adopts New Anti-Money Laundering Measures

At its April 23 meeting, the Nevada Gaming Commission unanimously approved amendments to Regulation 5 governing the operation of gaming establishments. The changes require casino compliance officers responsible for regulatory oversight to undergo vetting and licensing by regulators, increasing accountability for preventing money laundering activities.

Under the revised rules, the NGCB will review and approve individuals primarily responsible for overseeing a casino’s anti-money laundering (AML) program, as well as employees working in player development. Employees with compliance responsibilities must now be licensed, and new restrictions have been placed on business entities that fund patrons’ wagering activities. Furthermore, AML compliance officers are classified as gaming employees and must register accordingly.

The amendments also require gaming companies to notify the Board when an employee is terminated for violations related to AML policies. In addition, the rules establish requirements for secondary representatives with AML training for independent agents and mandate reporting of dismissals tied to AML violations.

George Assad Wants to See Even More Measures

Assad praised the new regulations, saying the measures should help regulators avoid having to place individuals in the state’s Black Book. The Black Book he is talking about refers to the list, formally known as Nevada’s List of Excluded Persons, which prohibits individuals considered a threat to the integrity of the state’s gaming industry from entering casinos. In fact, the Nevada Gaming Control Board (NGCB) has recently been considering updating the Black Book.

However, to further bolster AML measures, Assad suggested establishing a whistleblower program that would reward individuals whose information leads to the capture of money-laundering offenders or fraudsters. He proposed offering a 1% reward tied to seized funds, noting that a case involving $10 million could result in a $100,000 payout, creating a strong incentive for people to come forward. 

Assad also called for tougher enforcement of source-of-funds reviews, along with more rigorous verification and Know Your Customer (KYC) procedures rather than merely treating compliance as a box-checking exercise.

In addition, Assad described Nevada’s decision to cede Regulation 6A oversight to the federal government back in 2007 as a “bad idea.” He noted that the federal government already receives millions of Suspicious Activity Reports each year from banks, financial institutions, and casinos. Reports that come from Nevada casinos pretty much get lost in the shuffle, he argued.

Assad also urged that key provisions of Regulation 6A be incorporated into new rules that would enable the NGCB to receive information on suspicious financial activity, particularly involving high-rollers (“whales”) and large foreign transactions in casinos.

In other news regarding the NGCB, the organization is currently embroiled in a court battle with Kalshi over the legal standing of its sports events contracts.