Wynn Fined $5.5M Over Unlicensed Transactions in AML Crackdown: “Enough is Enough,” Says NGC

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Photo by Alexander Grey on Unsplash

The Nevada Gaming Commission (NGC) has approved a $5.5 million fine against Wynn Las Vegas, capping a series of contentious hearings into anti-money laundering (AML) failures on the Strip. While the vote passed 4-1, the sentiment in the room was anything but unanimous praise.

“A Body Blow” to Wynn’s Reputation

In a tense 90-minute session, NGC Commissioner George Markantonis pulled no punches, calling the six-count regulatory complaint against Wynn a “body blow” not only to the operator but to the commission itself. Markantonis, a former president of Las Vegas Sands, joined three others in approving the stipulated settlement — despite visible frustration over the case’s broader implications.

Only Commissioner Rosa Solis-Rainey voted against the deal, arguing the $5.5 million penalty paled in comparison to the gravity of the violations.

Allegations of a $130 Million Underground Network

At the heart of the complaint: a 2024 non-prosecution agreement with the US Department of Justice. Wynn agreed to forfeit $130 million to resolve accusations of facilitating funds transfers via unregistered money transmitting businesses — many linked to now-infamous figure Juan Carlos Palermo, an Argentinian national.

According to federal prosecutors, Palermo’s illicit operations spanned 15 countries and processed no less than $130.1 million for Wynn patrons. Between 2011 and 2020, he operated what was essentially an underground banking network. In one instance, Palermo transferred $200,000 from Uruguay to the US through layered accounts.

Wynn’s Defense: “Rogue Agents, Not a Systemic Failure”

Wynn Resorts claims these breaches were driven by rogue employees long since removed from the company. In Thursday’s hearing, legal counsel Eric Aldrian argued that Wynn’s internal policy at the time allowed independent agents to pay markers for patrons — a practice legal under Nevada law.

“The 200 transactions were absolutely visible to us… they did not skirt our AML programme,” said Aldrian.

Yet, despite blacklisting some of the shell entities used by these agents, Wynn continued transacting through alternate banking channels for years — even after knowing the agent was charging patrons a 6% commission.

Proxy Betting and “Flying Money” Schemes Exposed

The complaint also highlighted disturbing AML gaps. Wynn allegedly facilitated transactions for:

  • A known proxy gambler linked to a transnational crime syndicate
  • A former Chinese inmate involved in illicit financial transfers
  • Several “flying money” setups, where patrons received cash via intermediaries
  • Cases of “human head” gambling, where banned players used stand-ins to wager

In one scenario, a banned player stood only feet away from the proxy, coaching bets without handling chips.

A Pattern Across the Strip

Thursday’s session was the third in a trilogy of enforcement actions by the NGC. In March:

  • Resorts World Las Vegas paid $10.5 million for AML failures linked to illegal bookmaker Matt Bowyer
  • MGM Resorts followed with an $8.5 million settlement related to Bowyer’s operations on their premises

Both cases prompted public backlash over regulatory leniency. The Wynn case, while distinct in legal classification (non-BSA violations), fanned those flames further.

Commissioner Markantonis Draws the Line

As public confidence wavers, Markantonis issued a stark warning to operators:

“We are not taking prisoners anymore, enough is enough. The BS is over — it doesn’t matter how fancy your title is.”

His remarks reflect rising pressure on the NGC to demonstrate enforcement muscle against the Strip’s most powerful operators.

What’s Next?

Although the fine is finalized, the saga continues. Federal prosecutors still await sentencing decisions for Wayne Nix, Damien LeForbes, and Matt Bowyer. The NGC also granted a temporary license to Maurice Wooden of Fontainebleau Las Vegas, amid questions over potential AML violations at the new property.

As Commissioner Abbi Silver suggested, Wynn’s penalty may have closed a chapter — but the book on AML compliance in Las Vegas casinos is far from finished.

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