Nevada Gaming Commission Approves New Licensing Requirements for Certain Compliance Personnel

At its April 2026 meeting, the Nevada Gaming Commission approved amendments to Nevada Gaming Commission Regulations 5 and 25 addressing the licensing and registration of certain compliance and anti-money laundering (“AML”) personnel. These amendments follow the recommendations advanced earlier this year by the Nevada Gaming Control Board and represent the final step in that rulemaking process at the Commission level.

As previously discussed in our client alert, “Nevada Gaming Regulators Propose AML Reforms to Regulations 5 and 25,” the proposed changes were intended to strengthen individual accountability and formalize regulatory oversight of compliance and AML functions at Nevada gaming licensees. The Commission’s approval confirms that those proposals will be implemented, subject to final codification and effectiveness through the state’s regulatory process.

Under the approved amendments, the individual designated as primarily responsible for a licensee’s overall compliance program must be classified as a key employee and is required to obtain licensure or a finding of suitability by the Commission. In addition, individuals who primarily oversee a licensee’s AML program must be registered as gaming employees, formalizing regulatory oversight of those roles.

Licensees should review their existing compliance and AML organizational structures to identify whether current or future personnel will be subject to these licensing or registration requirements once the amendments become effective.

We will continue to monitor publication of the final adopted regulations and effective dates and will provide further updates as appropriate. If you have any questions about the issues raised in this alert, please contact the authors.