Culpability of Las Vegas Sands in spotlight as Nevada regulators approve $7.2 million Venetian AML fine

The Nevada Gaming Commission approved a $7.2 million anti-money laundering fine against the Venetian Resort Las Vegas Thursday, which represented the fourth such penalty against a Las Vegas Strip entity for AML failures related to illegal bookmaker and prolific gambler Mathew Bowyer since the start of 2025.

The Venetian case closely resembled the previous investigations involving Resorts World, MGM Resorts and Caesars Entertainment. All four failed to substantiate Bowyer’s source of funds, and the compliance departments for all four failed to adequately investigate and ban the convicted bookie from their respective premises. Including the Venetian, the four cases have resulted in $34 million in combined penalties.

This latest stain on Nevada’s premier industry also resembled those previous cases for other reasons, namely changes of ownership and regulatory conflicts of interest. Two of the five commissioners — George Markantonis and Richard Schonfeld — recused themselves from the Venetian matter, and the current owner of the resort, Apollo Global Management, accepted the fine even though the state’s investigation determined that most of the misconduct came from 2019-2021, when it was still owned by Las Vegas Sands.

Both of these dynamics were seen in previous cases. The MGM and Resorts World matters also featured recusals, and the Caesars case also dealt with an ownership transition where the current owners accepted penalties for wrongdoing on their predecessors’ account.

Markantonis served as president of the Venetian during the timeline of the Bowyer investigation. Schonfeld, a prominent criminal defense attorney, represented “an individual in a related investigation that has some overlap” with the Venetian case. While the remaining three commissioners gave boilerplate criticisms of the casino’s shortcomings, the settlement was approved unanimously.

Venetian ‘not as egregious’ as others

Given Markantonis’ direct connection to the case, he might have been a party to the investigation. Mike Somps, a senior deputy from the attorney general’s office, told commissioners that the Nevada Gaming Control Board determined the Venetian deserved leniency and that its conduct was “not as egregious” as the other Bowyer offenders. He listed five reasons for this rationale:

• The board determined there was not a “culture of non-compliance” or “ignoring” bookmakers
• The Venetian did not face a federal investigation for the violations
• The misconduct was “limited to Mr. Bowyer” and there was no evidence of “any other illegal bookmakers”
• The Venetian’s compliance department had “no information” about Bowyer’s illegal bookmaking
• The board found no evidence of “any senior executives having any knowledge” of Bowyer’s activity

That last point would seem to include Markantonis, given his role of president and COO of the property during the time of the investigation. When reached by iGB this week, a spokesperson for the commission declined to comment on Markantonis’ involvement in the matter.

Las Vegas Sands did not respond to multiple requests for comment about the investigation.

Schonfeld did not disclose the individual he referred to in his recusal. His defense firm, Chesnoff & Schonfeld, has represented several individuals accused of gaming-related crimes in Las Vegas, including David “Vegas Dave” Oancea and Paul Phua, who, like Bowyer, has immense connections to the underground sports betting world.

Sands blamed by current owners

In the period from 2019-2024, when Bowyer’s illicit business was at its peak, he visited the Venetian dozens of times and ultimately lost a total of $3.6 million at the casino, per the state’s investigation. The $7.2 million fine represented a doubling of that number, less severe than what others faced — Caesars’ $7.8 million fine, for example, represented a tripling of its $2.6 million Bowyer profit.

Representatives from the resort were contrite before the commission but distanced themselves from Sands’ transgressions. Greg Brower, an attorney representing the Venetian and a former Nevada state Senator, said that “nearly all of Bowyer’s activity at the Venetian occurred prior to” the casino’s 2022 sale to Apollo. Of the $3.6 million in Bowyer-related profits, Brower said less than $100,000 came during Apollo’s ownership.

“Since assuming ownership and control, the current licensee has done its very best to meet all of its state and federal legal and regulatory obligations, including its federal anti-money laundering obligations under the [Bank Secrecy Act],” Brower said.

Commissioners asked Brower and current Venetian CEO Patrick Nichols about Sands’ wrongdoing, for which they could only answer in vague terms. Brower noted that Sands delegated AML compliance to the corporate level, which Apollo felt was “not the most effective” strategy. Nichols asserted that the “big difference” between the two is that current management doesn’t retain players “if we have doubts on where money is coming from”.

NGCB Chair Mike Dreitzer was on hand to relay the board’s stance that the fine “fell in line with the appropriate reflection of severity for this case compared to others” related to Bowyer.

Continued frustrations with AML cases

Commissioner Brian Krolicki spoke at length during the meeting, though it seemed that his ire was mostly directed at Sands with nowhere to go. Krolicki has repeatedly voiced frustration at the frequency of AML problems before the commission and has hoped the fines will serve as a “clarion call” to the Strip.

“I suspect the folks I really want to have in front of me are not in front of me today,” Krolicki said, in apparent reference to Sands.

He later added that while the commission has the option to host a dedicated public hearing on the issue, it is unnecessary at this point. “But if previous management might be here, I may have a different opinion about that,” he quipped.

Commission Chair Jennifer Togliatti, a retired judge, said her experience in litigation has taught her to be “very careful not to step on a deal”. Nevada has a unique two-tiered regulatory system where the Gaming Commission has final authority over recommendations put forth by the Control Board. Dreitzer said Thursday that the Venetian investigation spanned a year and negotiations took an additional six months, which Togliatti was deferential to.

The four Bowyer-related AML cases have been approved by a total vote tally of 15-1, with the sole ‘no’ vote coming from former commissioner Rosa Solis-Rainey in the Caesars case. Solis-Rainey was replaced on the commission by Schonfeld in April at the conclusion of her term. The former commissioner told Casino Reports this month that she doesn’t believe the AML fines have “addressed the scope of what [casinos] allowed to occur sufficiently”.