G2E Panel Details $34 Million in Casino Fines for AML and KYC Failures

Regulators imposed $34 million in fines on casino operators in September for anti-money laundering and know-your-customer violations. A panel at the Global Gaming Expo examined the cases and the compliance shortcomings that produced them.

Melissa Gomez Nelson, partner with Dentons US, outlined the enforcement actions during the session titled “Identifying and Managing Emerging Financial Crime Risks.” One casino allowed a man to gamble on 80 separate days without verifying his source of funding. Others were cited for systemic AML oversight weaknesses and for ignoring a high-risk designation after receiving a tip.

“This is obviously a concerning issue because there were a lot of red flags that were flagged and issues that were raised within the operators’ organizations,” Nelson said. The casinos involved were not named.

Shift from Paper Programs to Demonstrated Effectiveness

Abigail Singley, PwC advisory director, said loosened enforcement has changed the standard. It is no longer enough to maintain the pillars of an AML program on paper. Singley stated that operators must demonstrate and implement a true risk-based program effective in identifying and actioning risk.

Elise Lebourg, Ernst & Young senior manager of Forensics and Integrity Services, said many programs have become checkbox exercises. She noted that genuine risk assessment asks whether the evaluation is accurate and whether it advances alongside the product roadmap instead of relying on arbitrary spreadsheet updates.

Dave Foppert, DraftKings Vice President, AML Officer, said policies have diminished to minimum requirements over the last 12 months. “I think we’ve all seen this over the last 12 months, where having a policy is the floor, not the ceiling,” Foppert said. He identified breakdowns in communication between compliance teams and marketing, product, and customer-facing units as a recurring factor in enforcement cases.

Risks Exposed by Static Risk Assessments

Lebourg said risk assessment forms the foundation yet gaps persist when assessments are not updated or when outputs fail to reach business units in usable form. Compliance teams often produce detailed assessments that prove hard to translate into operational changes. According to reporting by CDC Gaming, the panel made clear that regulators now examine effectiveness rather than documentation alone.

Operators cannot treat compliance as a periodic binder review. The cases show that unaddressed red flags and siloed functions invite regulatory action.

Reporting: CDC Gaming

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