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Harry Cassin
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Thomas Fox
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Las Vegas Sands pays $7 million to resolve FCPA criminal probe

Las Vegas Sands Corp. agreed Thursday to pay a criminal fine of nearly $7 million for Foreign Corrupt Practices Act offenses in China and Macau.

The casino and resort operator admitted that from 2006 through 2009, it paid $5.8 million to a China consultant “without any discernable legitimate business purpose.”

A finance department employee and an outside auditor warned Las Vegas Sands that some of the money paid to the consultant couldn’t be accounted for.

Las Vegas Sands fired the employee and paid the consultant more money.

According to the DOJ,

[C]ertain Sands executives knowingly and willfully failed to implement a system of internal accounting controls to adequately ensure the legitimacy of payments to a business consultant who assisted Sands in promoting its brand in Macau and the PRC, and to prevent the false recording of those payments in its books and records.

In April 2016, Las Vegas Sands settled civil FCPA charges brought by the SEC. The company paid a $9 million penalty in that action. It didn’t admit or deny the SEC’s findings.

The SEC said Las Vegas Sands spent more than $62 million on the China consultant. The consultant acted as an intermediary to hide the company’s role in buying a basketball team and a building in China, the SEC said.

Billionaire Sheldon Adelson founded Las Vegas Sands Corp. in 1988 and still runs it.

In Thursday’s enforcement action, the DOJ gave the company a non-prosecution agreement (pdf). Las Vegas Sands also received a 25 percent reduction off the bottom of the applicable U.S. Sentencing Guidelines fine range. The DOJ said the company “fully cooperated in the investigation and fully remediated.” 

The remediation included hiring a new general counsel and new heads of internal audit and compliance. The company set up a new board of directors compliance committee and increased the compliance and accounting budgets.

Las Vegas Sands also updated its code of business conduct and anti-corruption policy, and adopted new guidelines for comping government officials and reimbursing employee expense accounts. It started more compliance training and upgraded how it screens third parties and new hires.

None of the people implicated in the FCPA offenses are still with the company, the DOJ said Thursday.


Richard L. Cassin is the publisher and editor of the FCPA Blog.

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1 Comment

  1. Did DOJ consider any kind of redress to the finance department employee who warned Las Vegas Sands and as a consequence he/she got fired?

    This is part of a much bigger issue that is rarely addressed in any such corruption proceedings. The issue is: Most of the corrupt practices deprive corporations and individuals who opt not following corrupt practices. A large number of direct and indirect employees of such corporations suffer due to the business lost to corrupt corporations. Is there a mechanism that can redress such sufferings any time later when the corruption is discovered and culprits are punished (mostly through DPA) and hefty fines are imposed?

    Jafar Hyder

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