Wynn Las Vegas Money Laundering Settlement: $130M Federal, $5.5M Nevada

The Wynn Las Vegas money laundering settlement resolved federal and Nevada state investigations into a years-long scheme in which casino employees helped foreign gamblers move cash through unlicensed money transmitters. Wynn agreed in September 2024 to forfeit $130,131,645 to the U.S. government under a non-prosecution agreement with the U.S. Attorney’s Office for the Southern District of California, the largest criminal forfeiture ever imposed on an American casino. Nevada regulators added a $5.5 million fine in May 2025, bringing the total to roughly $135.6 million.¹

What the Federal Deal Requires

The non-prosecution agreement was announced on September 7, 2024. Wynn admitted that the prosecutors’ statement of facts was “true and accurate” and accepted responsibility for the conduct of its former employees and agents. The forfeiture is technically a return of funds involved in the illegal transactions rather than a fine, a distinction the company has emphasized publicly.² Payment came in two equal installments, the first due September 27, 2024, and the second on February 27, 2025.³

In exchange, the Justice Department agreed not to bring criminal charges against the company, provided Wynn complies with a set of obligations over a two-year period. Those obligations include:

Maintaining an independent compliance committee of at least three members who are not company employees or board members
Employing a chief global compliance officer
Enhancing the anti-money laundering program across all Wynn properties
Upgrading compliance training and technology
Submitting to an external compliance review with written progress reports to federal prosecutors

The investigation was led by Homeland Security Investigations and IRS Criminal Investigation, with support from the DEA and the Las Vegas Financial Crimes Task Force. Fifteen other defendants had already admitted to related crimes and paid penalties exceeding $7.5 million before the agreement with Wynn was finalized.¹

What Nevada Added

The Nevada Gaming Control Board opened its own regulatory case into the same conduct. On May 15, 2025, the Board filed a six-count complaint against Wynn Las Vegas alleging “unsuitable methods of operation,” including allowing unregistered money transmitting businesses, facilitating improper international monetary transactions, and permitting proxy betting, all in violation of the casino’s own anti-money laundering compliance program.⁴

A stipulated settlement announced the same day required Wynn to pay $5.5 million to Nevada’s General Fund and accept conditions on its gaming license, including further enhancements to its anti-money laundering program, additional staff training, and increased employee awareness requirements. The Nevada Gaming Commission approved the settlement on May 22, 2025, by a 4-1 vote. Board Chairman Kirk Hendrick said Wynn had provided “full cooperation” during the investigation.⁵

How the Schemes Worked

The federal investigation traced the conduct back to at least July 2014. Foreign high-rollers were moved around U.S. banking and anti-money laundering laws through three main methods.

The first used independent agents acting as unlicensed money transmitters. They recruited wealthy foreign gamblers and routed their funds through layers of shell companies, bank accounts, and nominees in Latin America and elsewhere before depositing them into Wynn-controlled accounts in San Diego and ultimately into the casino’s internal bank, known as the “cage.” The most prominent agent, Juan Carlos Palermo, ran operations in at least 15 countries and conducted more than 200 transfers totaling over $17.7 million on behalf of at least 50 patrons between 2012 and 2020.⁶

The second was “human head” gambling, from the Chinese ren tou. A proxy sat at the table and placed bets on behalf of a patron who could not or would not gamble under their own name because of anti-money laundering restrictions. The true patron often stood behind the proxy to direct play.³

The third, called “flying money” (qian chen), worked as a parallel currency exchange. A processor in the United States handed cash to a foreign gambler who could not otherwise access U.S. dollars. The gambler then transferred an equivalent amount in their home currency to the processor’s overseas accounts, often through mobile apps like WeChat.⁷

Wynn’s marketing hosts were central to the operation. According to the non-prosecution agreement, hosts and managers introduced patrons to money processors, arranged private handoffs of cash in hotel rooms and vehicles, and in at least one instance stored $3 million of a patron’s cash in a personal safe. Some hosts received a cut of the commissions generated by the processors. The casino also failed to file Suspicious Activity Reports despite clear red flags, including facilitating $1.4 million in transactions for a person who had previously been denied entry to the United States over suspected criminal ties.¹

A CNN investigation published in November 2025 reported that much of the cash flowing through these networks originated with Mexican drug cartels. Four Chinese nationals living in Las Vegas — Lei Zhang, Bing Han, Liang Zhou, and Fan Wang — served as middlemen, accepting cash from anyone who wanted to avoid the banking system, including people connected to fentanyl trafficking, human smuggling, and prostitution. Former DEA agent Chris Urben described the cash as funds that “forty-eight hours ago … was the proceeds of fentanyl.” All four were charged in 2019, pleaded guilty by 2020, and received sentences ranging from three months of home detention to 15 months in prison.⁷

What Wynn Has Said

Wynn Resorts publicly acknowledged that “several former employees facilitated the use of unlicensed money transmitting businesses, which both violated our internal policies and the law, and for which we take responsibility.” The company said the federal settlement let it “put legacy issues fully behind us and focus on our future.”⁸ When Nevada announced its fine, the company described the violations as actions “undertaken by individuals with whom we severed ties years ago.” Wynn has emphasized that none of the employees involved remain on staff, that it has installed a new executive team and board of directors, and that it has upgraded its compliance infrastructure. The non-prosecution agreement was signed by Ellen F. Whittemore, executive vice president and general counsel for Wynn Resorts, who certified that the board had reviewed the terms.³

Part of a Wider Nevada Crackdown

Wynn’s penalties sit inside a broader wave of anti-money laundering enforcement against Las Vegas operators. Over roughly nine months in 2025, the Nevada Gaming Commission approved three other fines: $10.5 million against Resorts World Las Vegas in March, $8.5 million against MGM Resorts in April, and $7.8 million against Caesars Entertainment in November. Including the $5.5 million from Wynn, the commission accepted more than $32 million in anti-money laundering penalties in 2025 alone.⁹ Ian Messenger, CEO of the Association of Certified Gaming Compliance Specialists, told CNN that casinos “haven’t received as much scrutiny as financial institutions have in the past. That is changing, with cases like Wynn.”⁷

What Happens Next

Wynn Las Vegas remains under the federal compliance term through September 2026. Throughout that window, the company must submit to external compliance reviews, remediate any deficiencies the reviewers find, and file written progress reports with federal prosecutors. If Wynn meets its obligations, the Justice Department will not bring criminal charges over the underlying conduct.³

1
ICE.gov. Wynn Las Vegas Forfeits $130M for Illegally Conspiring With Unlicensed Money Transmitting Businesses
2
KTNV. Wynn Resorts Paying $130M for Letting Illegal Money Reach Gamblers at Its Las Vegas Strip Casino
3
San Diego Union-Tribune. Wynn Las Vegas Forfeits $130M in Non-Prosecution Deal With San Diego Prosecutors
4
The Nevada Independent. Wynn Agrees to Settle Anti-Money Laundering Violation, Pay $5.5 Million Fine to Nevada Regulators
5
Nevada Gaming Control Board. News Release: NGCB and Wynn Las Vegas Stipulation for Settlement
6
Department of Justice. Illicit Money Transmitters Admit to Criminal Scheme to Funnel Money to Nevada Casino
7
CNN. Chinese Gambling, Wynn Casinos, and Cash Middlemen
8
ABC27 (AP). Wynn Resorts Paying $130M for Letting Illegal Money Reach Gamblers at Its Las Vegas Strip Casino
9
The Nevada Independent. MGM Resorts to Pay $8.5M Fine to Settle Role in Money Laundering Case