Nevada Casino AML Rules for Independent Agents Take Effect
Amendments to Nevada Gaming Commission Regulation 25 governing casino independent agents took effect on 21 August 2026, introducing new anti-money laundering training, due diligence, documentation and source-of-funds requirements for gaming licensees and the agents who act on their behalf.
The Nevada Gaming Control Board said the amendments were adopted on 23 April 2026 and became effective 120 days later. Regulation 25 applies to independent agents who, among other things, are authorised to provide customer incentives exceeding $10,000 in a calendar year, receive compensation from a gaming licensee for their services, approve or grant gaming credit, or collect debts evidenced by credit instruments.
AML training and due diligence become explicit requirements
Under the amended rules, casino licensees must provide AML training when an independent-agent contract begins and annually thereafter. The licensee must also conduct due diligence on the independent agent, whether the agent operates as an individual or through a company.
For registration and renewal applications, licensees must submit additional AML documentation when transmitting a completed application to the Gaming Control Board. The application package now includes Form 26, the AML Training and Due Diligence Acknowledgement, completed by the licensee, and Form 25, the AML Acknowledgement, completed by each individual listed on Form 1R. Regulation 25 requires the licensee to transmit a complete registration or renewal application to the Board within 60 days after receiving the complete filing.
When a licensee enters into a new agreement with an already registered independent agent, the licensee must also submit Form 26 with the notification to the Board.
New controls on secondary representatives and source of funds
The amended requirements also address secondary representatives used by independent agents. An agent may not use a secondary representative unless the licensee has been notified of that person’s identity and has provided written approval.
Independent agents and their secondary representatives are prohibited from engaging in gaming transactions with the licensee on behalf of the agent’s client. The Board’s guidance defines a gaming transaction broadly as a transaction involving or facilitating wagering activity. The restriction does not prevent an authorised independent agent from approving or granting credit on behalf of the licensee, collecting a debt evidenced by a credit instrument, or extending complimentary benefits.
A particularly relevant AML provision allows the licensee to withhold compensation, including commissions, linked to an independent agent’s patron when the casino cannot establish or verify the patron’s legitimate source of funds.
Independent agents and secondary representatives must complete annual training on the licensee’s AML programme and acknowledge completion. Licensees are required to retain those acknowledgements for five years.
The effective date turns the April amendments from a future implementation requirement into an operational obligation for Nevada gaming licensees. For AML teams, the changes place greater emphasis on extending due diligence, training and source-of-funds controls beyond the casino’s direct employees to intermediaries involved in customer acquisition, credit and patron relationships.
