The Nevada Gaming Control Board (“Board”) recently filed a complaint (“Complaint”) against Resorts World Las Vegas casino (“Resorts World”), alleging that, despite repeated red flags, Resorts World’s Anti-Money Laundering (“AML”) Committee, executives, and other employees failed to bar Matthew Bowyer and other individuals who were patrons of Resorts World while being suspected of engaging in illegal bookmaking and other illicit activities.
The Board is seeking fines, actions against Resorts World’s licenses, and the appointment of a supervisor if the Nevada Gaming Commission (the “Commission”) revokes or suspends Resorts World’s gaming license. The Complaint is the latest development in a series of recent high-profile enforcement actions implicating major gaming institutions and the alleged use of the institutions to launder illegal bookmaking funds by high-end clients, with the institutions’ alleged tacit consent.
Bowyer came to the attention of both the Nevada Gaming Control Board and the Department of Justice (“DOJ”) following the investigation and guilty plea of Ippei Mizuhara, the Japanese-language interpreter and de facto manager of baseball superstar Shohei Ohtani. One of Bowyer’s clients was Mizuhara, who allegedly placed at least 19,000 bets with Bowyer’s illegal gambling business. Bowyer, in turn, allegedly took the proceeds of his bookmaking business and wagered millions of dollars at Resorts World.
The Commission
The Commission maintains oversight and control over the Nevada gaming industry, including Las Vegas casinos. The Board, meanwhile, has the authority to determine whether a violation of Nevada’s Gaming Control Act has occurred. The Board is authorized to observe the conduct of licensees, such as casinos, to ensure that gaming operations are not operated in an unsuitable manner or unsuitable person. If the Board believes discipline is warranted, then it may file a complaint with the Commission, as it has here with Resorts World.
The Bank Secrecy Act (“BSA”) of course requires casinos to develop and implement an effective AML compliance program reasonably designed to assure compliance. As part of a casino’s compliance obligations under the BSA, it must know its customers and their sources of funds as appropriate, using a risk-based approach. Even though casinos are regulated under the BSA by the Financial Crimes Enforcement Network and examined for BSA compliance by the Internal Revenue Service, the Commission and the Board – like other state gaming regulators – also maintain oversight over casinos to ensure their compliance with federal law and AML obligations.
The Complaint
Throughout its Complaint, the Board alleges that Resorts World’s executives and employees knew, or should have known, that certain individuals, including Bowyer, were illegal bookmakers or engaged in illegal activities. Additionally, Resorts World failed to fulfill the purpose of its AML program, and failed to comply with various specific provisions in its AML compliance program.
First, Resorts World allegedly failed to confirm Bowyer’s self-reported source of funds from a real estate business. Bowyer was allowed to make a $1 million front-money deposit and wager during his first visit to Resorts World, although his source of funds had not yet been established.
Second, Resorts World AML Committee’s later evaluations stated on different dates that, “patron is a known ‘bookie’ and is using his spouse’s Independent Host business as a cover” and “possible sports betting affiliation.” Bowyer even informed a Resorts World employee that he “runs a book” and asked for client referrals in return for cash. A patron at Resorts World also told another casino employee that Bowyer was “taking action” as an illegal bookmaker. Likewise, the Complaint alleges that Bowyer’s stated source of legitimate funds did not justify his level of play, which involved wagering and losing millions of dollars.
Despite all of these red flags, and despite the alleged unilateral authority of certain executives to take action, Resorts World took no action to bar, ban or otherwise restrict Bowyer from Resorts World until a federal search warrant was executed at Bowyer’s home. Instead, Resorts World allegedly extended numerous benefits to Bowyer including encouraging him to play at Resorts World through comps, promo chips, gifts, discounts, and flights on Resorts World’s jet.
Other Patrons
In addition to Bowyer, the Complaint alleges that Resorts World allowed another illegal bookmaker, identified only as “Patron A,” to similarly bet and solicit clients through Resorts World. Although a Resorts World host allegedly understood that Patron A was an illegal bookmaker, he did not report this information to his supervisors at the casino because the host “thought that [he] was not the only one that kind of knew and it was kind of looked over.”
Finally, the Complaint alleges that Resorts World failed to bar two individuals with known connections to illegal gambling. Specifically, the Complaint focuses on Edwin Ting, who pleaded guilty in and was sentenced in 2014 in the Southern District of New York for conducting an illegal gambling business, but who became a patron of Resorts World when it first opened in 2021. Ting allegedly wagered on 21 separate days at Resorts World, losing over $800,000, until he was banned in August 2023 as a result of an internal review. The Complaint focuses on Chad Iwamoto, who pleaded guilty and was sentenced in 2014 in the District of Hawaii for illegal transmission of wagering information and failing to file tax returns; Iwamoto allegedly wagered on 52 separate days at Resorts World and lost over $2 million, until he was banned in April 2024.
The Complaint emphasizes that casinos must have effective BSA/AML programs, and that sufficient training and acting on red flags is critical. Beyond federal regulators and law enforcement, state gaming regulators are prepared to pursue enforcement to prevent illicit finance.
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