AML COMPLIANCE: STANDING FIRM AMID RISING CHALLENGES
At the 2025 IAGA Summit in Berlin, Nevada Gaming Commission Vice Chairman, Brian K. Krolicki, will highlight the state’s rigorous two-tiered regulatory system and its response to recent AML enforcement actions tied to illegal sports betting operations. Emphasising the US$98bn economic impact of the gaming industry in Nevada, Krolicki issues a clarion call for unwavering AML compliance, addresses the growing role of AI in combating financial crime, and underscores the importance of cross-sector collaboration, including efforts by the International Association of Gaming Regulators (IAGR) to harmonise global AML standards.
Can you briefly explain Nevada’s two-tiered gaming regulatory system?
Some historical context helps explain why Nevada regulates its world-renowned gaming industry through a unique two- tiered system. Although gambling was legalised in 1931 during the Great Depression, the industry remained largely unregulated for decades, creating opportunities for unscrupulous actors to finance and operate casinos. By the 1950s, as Las Vegas emerged as a global gaming hub, growing concerns about organised crime and corruption prompted state lawmakers to establish a more robust regulatory framework.
In 1955, the Nevada Gaming Control Board (NGCB) was created to serve as the investigative and enforcement arm—overseeing licensing, auditing, and day-to-day regulatory operations. In 1959, the Nevada Gaming Commission was established by the passage of the Gaming Control Act as the final decision- making body on licensing and disciplinary matters, providing an added layer of oversight and insulation from political or outside influence. Tis two-tiered model created vital checks and balances, ensuring regulatory integrity through independent review and accountability. Today, it stands as a widely emulated model for gaming regulation around the world. I currently serve on the NGC by gubernatorial appointment.
What are the unique anti-money laundering (AML) risks that the gambling industry faces compared to other sectors, and how do these risks differ between retail and online operations?
62
Te gambling industry faces distinct AML risks driven by the nature of its products and customer behaviours, with significant differences between retail (brick-and-mortar) operations and online platforms. Retail venues are especially vulnerable to traditional, cash-based money laundering, with anonymity posing a serious challenge, particularly in jurisdictions with weak know your customer (KYC) requirements. Te rapid flow of funds through bets, winnings, and withdrawals further complicates efforts to trace the origin of money. In contrast, online gambling faces heightened risks related to digital fraud, identity misuse, and cross-border financial transactions.
Tese operational differences shape how we manage AML risks. Online platforms often have an advantage in detecting suspicious activity through automated, real-time monitoring, while retail operators must often rely on manual systems. To address these risks, regulators require both sectors to implement core AML controls, including KYC protocols, transaction monitoring systems (TMS), suspicious activity reporting (SAR), and enhanced due diligence (EDD) for higher- risk scenarios.
In recent months, there have been significant regulatory activities by Nevada’s gaming regulators stemming from illegal sports betting activities originating in California. Can you elaborate?
Tese regulatory enforcement actions by the NGCB and the NGC stemmed primarily from AML failures tied to illegal sports betting operations based in California. Investigations
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72 |
Page 73 |
Page 74 |
Page 75 |
Page 76 |
Page 77 |
Page 78 |
Page 79 |
Page 80 |
Page 81 |
Page 82 |
Page 83 |
Page 84 |
Page 85 |
Page 86 |
Page 87 |
Page 88 |
Page 89 |
Page 90 |
Page 91 |
Page 92 |
Page 93 |
Page 94 |
Page 95 |
Page 96 |
Page 97 |
Page 98 |
Page 99 |
Page 100 |
Page 101 |
Page 102 |
Page 103 |
Page 104 |
Page 105 |
Page 106 |
Page 107 |
Page 108 |
Page 109 |
Page 110 |
Page 111 |
Page 112 |
Page 113 |
Page 114 |
Page 115 |
Page 116 |
Page 117 |
Page 118 |
Page 119 |
Page 120 |
Page 121 |
Page 122 |
Page 123 |
Page 124 |
Page 125 |
Page 126 |
Page 127 |
Page 128 |
Page 129 |
Page 130 |
Page 131 |
Page 132 |
Page 133 |
Page 134 |
Page 135 |
Page 136 |
Page 137 |
Page 138 |
Page 139 |
Page 140 |
Page 141 |
Page 142 |
Page 143 |
Page 144 |
Page 145 |
Page 146 |
Page 147 |
Page 148 |
Page 149 |
Page 150 |
Page 151 |
Page 152 |
Page 153 |
Page 154 |
Page 155 |
Page 156 |
Page 157 |
Page 158 |
Page 159 |
Page 160 |
Page 161 |
Page 162 |
Page 163 |
Page 164 |
Page 165 |
Page 166 |
Page 167 |
Page 168 |
Page 169 |
Page 170 |
Page 171 |
Page 172 |
Page 173 |
Page 174 |
Page 175 |
Page 176 |
Page 177 |
Page 178 |
Page 179 |
Page 180
