Caesars Entertainment outlined its efforts to eliminate regulatory violations in Nevada that resulted in a $7.8 million fine issued by the state Gaming Commission for having an illegal bookmaker as a customer. The company is working with others in the industry to address violations over which Las Vegas properties this year have paid similar multi-million-dollar fines.
The steps Caesars has been taking are in addition to ones that are part of the agreement approved Thursday with Nevada gaming regulators. The fine was based on allegations that it failed to track the source of funds of since-convicted bookie Matthew Bowyer. Caesars started implementing changes after Bowyer was arrested in January 2024.
Ed Quatmann, Caesars’s chief legal counsel, said the gaming operator has invested heavily in compliance and the anti-money-laundering team has full access to company data, analytics, and casino-management systems.
“Decisions are made in a way to avoid influence and interference,” Quatmann said. “We require annual training for all customer-facing team members, which includes testing and tracking for accountability purposes. Our AML headcount overall has increased considerably since this matter occurred. Our AML spend is roughly twice what it was in 2017.”
Quatmann said Caesars’s original list of banned persons included more than 7,000 people. Since its 2020 merger with Eldorado Resorts, they’ve added nearly 3,500 names.
Besides removing personnel involved who should not have allowed Bowyer to do business with the casino, Quattmann said Caesars terminated an arrangement with an independent agent involved in the matter. Quattmann also took over AML oversight as chief legal officer and a member of the executive team.
“I’m now serving as the AML officer and the Nevada compliance officer,” Quatmann said. “In this role, all high-risk source-of-funds decisions come to me. We’ve engaged a third-party expert to review our AML and KYC (Know Your Customer) protocols and the process is ongoing. And we’re exploring the use of enhanced data analytics and scrutiny of source-of-funds documentations. This matter has the direct focus our leadership team, Board of Directors, the compliance committee, and me” Quatmann said. “This activity has no place in Caesars and will not be tolerated.”
Caesars’s outside legal counsel Michael Alonso said the operator continues to bolster the effectiveness of its AML program to perform enhanced diligence on customers. He said they’re searching for an industry expert to lead its AML team.
“We’re further incorporating data analytics in the AML program to assist with the decision to bar, suspend, or ban patrons for AML reasons,” Alonso said. “We’re initiating additional inquiries into the customer database according to updated risk-rating methods. We lowered the threshold to obtain supporting documentation for large currency transactions performed at the properties. These records are then maintained in the patron’s files and subject to review by compliance team members.”
Some of the modifications to its AML program since 2024 include the Know Your Customer team’s conducting additional analysis to ensure high-risk patrons are reviewed and processed and referred upward in the company. “KYC is escalating all alerts with AML-related felonies, regardless of how long dated the felonies were as part of their management review,” Alonso said.
In October 2024, AML personnel attended a Banking Secrecy Act conference and created an 18-page training deck to summarize the conference, then administered it at every property.
In November 2024, Caesars implemented large-currency forms to change the amount to $50,000 in Las Vegas, which requires details of denominations and the condition of the currency and source of funds for new patrons.
In February 2026, when Seven Star high-level customers have income discovered to be from gambling, Caesars will run a request to compare if other operators have any AML concerns with the customer and whether they are banned, Alonso said. Also in February, in addition to requesting tax returns for high-net-worth patrons, the AML team may ask for IRS transmittals to validate them.
The AML team has increased the weight and value of bankruptcies for high-risk patrons if they happened in the last 10 years, Alonso said. Professional gamblers will also all be under greater scrutiny.
“It qualifies now as a standalone red flag and escalates patron risk,” Alonso said. “The AML team now considers the professional gambler to constitute a red flag, if the patron states income is from business and the tax returns show income are from gambling winnings.”
In March, the AML leadership updated procedures for Las Vegas to include a KYC report for any new front money of $25,000 or greater, Alonso said.
“Nearly every one of the improvements that Mr. Alonso walked through, you can directly tie to something that happened here with this incident,” Quatmann told the Commission. “One of the things he mentioned is better communication between the credit and AML teams. The credit team understood that Bowyer had been banned in other places, but that communication wasn’t as good as it can and should be with the rest of the house. That’s an improvement we implemented. There are more. This is the tip of the iceberg for what we’re doing. Everything we’re doing is in addition to the conditions (imposed by the Commission), which we will comply with.”
