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At the February 2026 meeting, the Nevada Gaming Control Board (NGCB) recommended a suite of "groundbreaking" amendments to Regulations 5 and 25 designed to bolster anti-money laundering (AML) requirements and oversight. Chairman Mike Dreitzer said the regulatory changes were the result of a “multi-month effort” that involved both the gaming industry and outside AML experts. “We looked at any number of risk areas, and these were the risk areas that made the most sense” to address, Dreitzer said.

Regulation 5: Operation of Gaming Establishments

The proposed amendments to Regulation 5 focus on individual accountability, the formalization of compliance roles, and stricter controls over the funding of patron accounts.

  • Licensing of Compliance Personnel:  A new provision will require the person responsible for a licensee's compliance to be designated as a key employee, meaning they must be formally licensed or found suitable by the Commission. Within 30 days of assuming their compliance responsibilities, the individual must file an application for licensure or a finding of suitability. This filing includes a submission of  a Multi-Jurisdictional Personal History Disclosure Form, which is one of several required forms in the licensure and suitability process, and requires detailed personal, employment, financial, litigation, criminal, and licensing history. Additionally, those overseeing AML programs must now register as a gaming employee, which is simple process and is completed in a short period of time.
  • Designated AML Accountability: Compliance plans must designate specific individuals with primary responsibility for the AML program and for player development (marketing) functions within 30 days of a change in personnel. These designations are subject to administrative review and approval.
  • Prohibition on Business Entity Funding: Regulation 5.047 now prohibits business entities from funding a patron's wagering activities via front money, wagering accounts, or credit payments.
  • Reporting AML Violations: Licensees are now required to notify the Board within 10 business days if a gaming employee is terminated or separated for "intentional or willful violations" of AML policies.

Regulation 25: Independent Agents

The proposed changes to Regulation 25 introduce tighter controls over independent agents and creates a new category of "secondary representatives."

  • Secondary Representatives: A new definition was established for individuals who assist or are compensated by independent agents but are not independent agents themselves.
  • Enhanced Due Diligence and Training: Licensees must now conduct due diligence on independent agents before entering an agreement and provide them with annual AML training. Acknowledgments of this training and the due diligence findings must be submitted to the Board.
  • Mandatory Agreement Conditions: All agreements with independent agents must now include provisions that:
    • Prohibit the use of secondary representatives without the licensee's prior approval.
    • Prohibit the agent or secondary representative from engaging in gaming transactions on behalf of a client.
    • Allow the licensee to withhold compensation if they are unable to verify a patron's source of funds.
  • Implementation Note: Most Regulation 25 changes will become effective 120 days after adoption to allow for the update of internal procedures and training programs.

Recent Enforcement Activity Providing Context for AML Reforms

The NGCB’s proposed amendments arrive against the backdrop of a series of high-profile AML enforcement actions that have exposed significant compliance breakdowns at major Nevada casinos over the past two years. Collectively, these matters reflect failures around source-of-funds verification, oversight of high-risk patrons, and accountability within casino compliance and marketing functions.

International Gaming Operator A – $10.5 million fine (March 2025).
Nevada regulators imposed one of the largest fines in state gaming history after finding that the operator permitted illegal bookmakers to gamble millions of dollars over an extended period without adequately verifying sources of funds or escalating red flags.

International Gaming Operator B – $8.5 million fine (April 2025).
The operator agreed to a substantial settlement following findings that illegal bookmakers were allowed to gamble and settle markers in cash at multiple Strip properties.

International Gaming Operator C – $5.5 million fine (May 2025).
The operator reached a stipulated settlement with the NGCB for violations involving unregistered international money transmissions, proxy betting, and the use of third-party intermediaries to move funds outside approved AML controls

International Gaming Operator D – $7.8 million fine (November 2025).
Regulators sanctioned the operator for long‑running AML failures tied to an illegal bookmaker who gambled at several affiliated properties over a period exceeding seven years.

Taken together, these enforcement actions, totaling more than $30 million in fines, illustrate the risk areas the NGCB now seeks to address through its proposed amendments: clearer individual accountability, formalized compliance authority, tighter controls over third-party and agent relationships, and enhanced oversight of patron funding sources.

 

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