Las Vegas Sands Settles $7M Foreign Corruption Probe

Las Vegas Sands Corp, the casino company owned by Sheldon Adelson, has just agreed to settle a federal corruption investigation related to its Macau business for $6.96 million. While the case would seem more a matter for the Chinese government, it is still of interest to US federal authorities as the Foreign Corrupt Practices Act prohibits its businesses and citizens from paying bribes to government official of foreign countries, regardless of local laws.
Between 2006 to 2009, Las Vegas Sands sent around $60 million to a consultant in order to help promote its brand in Macau, China’s only legal gambling resort, with the employee receiving about $5.8 million for his services. However, according to subsequent settlement papers, the funds had no “discernible legitimate business purpose”, and furthermore “the business consultant had failed to account for portions of these funds.”
Following the federal investigation, Las Vegas Sands has now agreed to a settlement without having to admit to any crime or guilt, with the fine levied by the government a full 25% lower than the minimum suggested under federal guidelines. According to the Justice Department, the reduced penalty apparently reflected the cooperation and “extensive” remedial measures subsequently carried out by Las Vegas Sands, and commenting on the conclusion of the case, Las Vegas Sands spokesman Ron Reese sent an email to Reuters, stating:
“The company is pleased that its cooperation and long-term commitment to compliance were recognized in reaching this resolution. We are equally pleased that all inquiries related to these issues have now been completely resolved.”
The latest $6.96 million penalty follows a $9 million civil payment made by Las Vegas sands in April of 2016 in order to settle allegations by the US Securities and Exchange Commission that it carried out poor accounting controls from 2006 to 2011. Once again, the case was related to its business activities in China, with $62 million in consultant payments apparently not properly account for. As Andrew J. Ceresney, Director of the SEC Enforcement Division, subsequently concluded at the time:
“Publicly traded companies must have appropriate financial controls in place to ensure that expenses are paid for bona fide services. Las Vegas Sands failed to implement controls to prevent tens of millions of dollars from being paid out without appropriate documentation or authorization.”

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