Compliance Confidential, Part Five: No Comment: Inside The Gaming Industry's Wall Of Silence

Nevada Gaming Control Board complaints issued in response to the recent anti-money laundering scandal in Las Vegas vaguely refer to countless casino employees whose behavior contributed to problems on the Strip: Wynn employees acting with the approval of their supervisors who conspired to circumvent the financial system, Caesars staff that failed to properly scrutinize bookie Mathew Bowyer’s source of funds, etc.

But the complaints also document the actions of at least 15 specific employees at Resorts World, the MGM Grand, The Cosmopolitan, The Venetian, and the Wynn who appear to have violated or contributed to violations of AML standards.

Those include hosts who referred clients to bookies, a Resorts World executive who stood up for Bowyer in a compliance committee meeting, an MGM Resorts executive director of compliance who declined to adopt auditors’ recommendations, a Venetian host who knew Bowyer was a bookmaker but didn’t report it, and a Wynn employee who referred a patron to an independent agent who could obscure the origin of money the patron wanted to use to pay off his markers.

All but one of those individuals have remained anonymous in court and regulatory records. The only one authorities have outed is former Cosmo host Jeremiah Chambers, whose role in referring Yasiel Puig to bookie Wayne Nix was revealed in the former Major League Baseball player’s trial this year.

The rest have avoided formal, public accountability while former Resorts World president Scott Sibella became the sole face of the scandal.

AML expert Joe Ciccolo said that raises concerns that bad actors may continue to work in the industry.

“A lack of transparency leads to speculation,” he said. “If we want to get better at AML, we have to hold the line in terms of potential consequences.”

Then again, secrecy is part of the culture of Las Vegas gaming.

Opacity in self defense

Operators regularly tell their employees not to speak publicly about the industry and even try to restrict their speech through non-disclosure agreements. The social pressure to remain silent is so strong that even after leaving the field it’s assumed former gaming employees will think twice about speaking out if their spouse still works in the industry.

Casino Reports tried talking to at least 50 current and former gaming or gaming-adjacent workers for this series with little success. (A lot of emails and voicemails were not returned.)

Likewise, experts interviewed as part of this reporting frequently avoided assigning blame or directly criticizing anyone or anything when asked about documented operator violations or the effectiveness of enforcement actions or compliance policies.

George Assad, an NGCB member touted for promoting the importance of AML compliance, said changing the culture in the Silver State was necessary “to keep the federal government out of the proverbial tent.” Assad later told Casino Reports he intended the comment to drive home that Nevada can handle its own issues and there is no need for a federal gaming commission or a federal gaming tax.

Taken together, these examples suggest an entrenched culture of secrecy and discretion and closed-door problem solving in an industry and community highly protective of its public image. Who in the gaming business hasn’t heard something about the importance of protecting the industry’s reputation?

This instinct to conceal may be understandable for a sector that’s still trying to distance itself from its historic mob ties. But UNLV professor Shane Kraus said it doesn’t help the industry.

“It’s really not a good playbook, if I’m being honest. They should be more transparent,” said Kraus, a problem gambling researcher.

“It’s really a risk aversion” — an attempt by the industry to avoid litigation and accountability, he said. “But I think the problem is that if you’re not trying to be transparent, if you’re not kind of showing and demonstrating to the public that you’re committed to really minimizing harms or addressing illegal behavior, then you actually in a sense are causing more scrutiny, you invite more scrutiny and more concern.”

‘Woulda, coulda, shouldas’

Representatives of Caesars, Resorts World, MGM, and Wynn declined to comment for this series of articles. The Venetian didn’t respond to requests for comment.

Mike Dreitzer, the NGCB chair, told Casino Reports he believes operators foster environments where employees may speak freely. He said, “It would be unfair to just stamp that as the culture is this or that.”

“I can just, as a regulator, go by what I see,” he said, adding that he encourages anyone to come to the NGCB if they have concerns. “We get a lot of information at all levels of the organization,” he said. “Licensees, we’re getting information from them.”

While researching this series, Casino Reports encountered an individual whose story challenged the narrative that lax compliance personnel allowed Bowyer to run amok.

This person, whose professional biography documents extensive compliance certifications and decades of experience in the gaming industry, described the efforts of two Strip resorts to vet Bowyer and his source of funds, including one property that received an anonymous tip about him being a bookie.

The source said both efforts were genuine and thorough, but neither found any actionable information to call for Bowyer’s ouster. Due diligence showed that his substantial winnings from other resorts covered his action. No evidence was found of Bowyer’s bookmaking — and the casino got lots of anonymous tips about other things that proved groundless.

To this person, the idea that compliance had fallen asleep at the switch was patently false. But the source declined to speak on the record for fear it might affect their job in AML.

“It’s easy afterwards to call woulda, coulda, shouldas, you know?” the source told Casino Reports. As for the regulators and investigators criticizing compliance staff, “They’re just grabbing at straws, coming in after the fact,” the person said.

But the source was adamant that speaking out was too dangerous, even if it meant failing to set the record straight and address the real problems at the root of the scandal.

“I don’t want to be blackballed in the industry,” the source said.

Next, in the final installment of the series: An investigative reporter’s analysis of an exercise in crisis management.