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FCPA Scorecard Blog

Foreign Corrupt Practices Act & Anti-Corruption

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  • Nevada Casino Operator Settles Civil Suit Related to FCPA Allegations

    On June 1, the Wall Street Journal reported that Las Vegas Sands, the Nevada-based operator of numerous hotel, resort, and casino properties in the United States and Asia, had agreed to settle a civil lawsuit originally filed in 2010 by a former executive.  In the suit, the plaintiff had made various allegations about Las Vegas Sands’ CEO exerting allegedly improper leverage over government officials in Macau.  While no independent verification of the settlement amount is available, the Wall Street Journal reported that Sands will pay between $75 and $100 million to settle the civil suit.  In April of 2016, Sands settled with the SEC over allegations that the company had violated the FCPA’s internal controls and books and records provisions related to activities in China and Macau, and agreed to pay a $9 million penalty and obtain an independent monitor for two years.  See previous FCPA Scorecard coverage of the settlement here.

    Las Vegas Sands

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  • Nevada Casino Operator Settles FCPA Allegations with SEC

    On April 7, 2016, the SEC settled FCPA allegations with Las Vegas Sands, the Nevada-based operator of numerous hotel, resort, and casino properties in the United States and Asia. In a cease and desist order, the SEC found that Las Vegas Sands violated the FCPA's internal controls and books and records provisions related to activities in China and Macau.  The SEC order alleged that Las Vegas Sands made more than $62 million in payments to a consultant in Asia, without supporting documentation or appropriate authorizations, and at times continued to make payments to the consultant without being able to account for prior transfers. Las Vegas Sands consented to the SEC's order without admitting or denying the charges and agreed to pay a $9 million dollar penalty.  In addition to the penalty, Las Vegas Sands agreed to obtain an independent monitor for two years to "review its FCPA-related internal controls, recordkeeping, and financial reporting policies and procedures and its ethics and compliance functions."

    Las Vegas Sands

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