Nevada Gaming Regulators Suggest AML Reforms to Regulations 5 and 25 | Womble Bond Dickinson

At the February 2026 assembly, the Nevada Gaming Control Board (NGCB) really useful a collection of “groundbreaking” amendments to Regulations 5 and 25 designed to bolster anti-money laundering (AML) necessities and oversight. Chairman Mike Dreitzer stated the regulatory modifications had been the results of a “multi-month effort” that concerned each the gaming trade and out of doors AML specialists. “We looked at any number of risk areas, and these were the risk areas that made the most sense” to deal with, Dreitzer stated.

Regulation 5: Operation of Gaming Establishments

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

• Licensing of Compliance Personnel:  A brand new provision would require the individual chargeable for a licensee’s compliance to be designated as a key worker, which means they have to be formally licensed or discovered appropriate by the Commission. Within 30 days of assuming their compliance obligations, the person should file an software for licensure or a discovering of suitability. This submitting features a submission of  a Multi-Jurisdictional Personal History Disclosure Form, which is one in all a number of required varieties within the licensure and suitability course of, and requires detailed private, employment, monetary, litigation, prison, and licensing historical past. Additionally, these overseeing AML packages should now register as a gaming worker, which is easy course of and is accomplished in a brief time frame.
• Designated AML Accountability: Compliance plans should designate particular people with main duty for the AML program and for participant improvement (advertising) features inside 30 days of a change in personnel. These designations are topic to administrative evaluation and approval.
• Prohibition on Business Entity Funding: Regulation 5.047 now prohibits enterprise entities from funding a patron’s wagering actions by way of entrance cash, wagering accounts, or credit score funds.
• Reporting AML Violations: Licensees are actually required to inform the Board inside 10 enterprise days if a gaming worker is terminated or separated for “intentional or willful violations” of AML insurance policies.

Regulation 25: Independent Agents

The proposed changes to Regulation 25 introduce tighter controls over unbiased brokers and creates a brand new class of “secondary representatives.”

• Secondary Representatives: A brand new definition was established for people who help or are compensated by unbiased brokers however will not be unbiased brokers themselves.
• Enhanced Due Diligence and Training: Licensees should now conduct due diligence on unbiased brokers earlier than getting into an settlement and supply them with annual AML coaching. Acknowledgments of this coaching and the due diligence findings have to be submitted to the Board.
• Mandatory Agreement Conditions: All agreements with unbiased brokers should now embrace provisions that:
  • Prohibit using secondary representatives with out the licensee’s prior approval.
  • Prohibit the agent or secondary consultant from participating in gaming transactions on behalf of a consumer.
  • Allow the licensee to withhold compensation if they’re unable to confirm a patron’s supply of funds.
• Implementation Note: Most Regulation 25 modifications will turn into efficient 120 days after adoption to permit for the replace of inside procedures and coaching packages.

Recent Enforcement Activity Providing Context for AML Reforms

The NGCB’s proposed amendments arrive in opposition to the backdrop of a collection of high-profile AML enforcement actions which have uncovered vital compliance breakdowns at main Nevada casinos over the previous two years. Collectively, these issues replicate failures round source-of-funds verification, oversight of high-risk patrons, and accountability inside on line casino compliance and advertising features.

International Gaming Operator A – $10.5 million high-quality (March 2025).
Nevada regulators imposed one of many largest fines in state gaming historical past after discovering that the operator permitted unlawful bookmakers to gamble tens of millions of {dollars} over an prolonged interval with out adequately verifying sources of funds or escalating purple flags.

International Gaming Operator B – $8.5 million high-quality (April 2025).
The operator agreed to a considerable settlement following findings that unlawful bookmakers had been allowed to gamble and settle markers in money at a number of Strip properties.

International Gaming Operator C – $5.5 million high-quality (May 2025).
The operator reached a stipulated settlement with the NGCB for violations involving unregistered worldwide cash transmissions, proxy betting, and using third-party intermediaries to maneuver funds exterior authorised AML controls

International Gaming Operator D – $7.8 million high-quality (November 2025).
Regulators sanctioned the operator for lengthy‑working AML failures tied to an unlawful bookmaker who gambled at a number of affiliated properties over a interval exceeding seven years.

Taken collectively, these enforcement actions, totaling greater than $30 million in fines, illustrate the danger areas the NGCB now seeks to deal with by way of its proposed amendments: clearer particular person accountability, formalized compliance authority, tighter controls over third-party and agent relationships, and enhanced oversight of patron funding sources.

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