Foreign Corrupt Practices Act: Enforcement Action Dataset

Initiation Date: 04/07/2016

Prosecuting Agency: U.S. Securities and Exchange Commission

Type of Action: SEC Administrative Proceeding

Docket or Case Number: 3-17204

Name of Prosecuting Attorneys: Unknown

US Assisting Agencies:

U.S. Department of Justice
Federal Bureau of Investigation
Nevada Gaming Board

Foreign Enforcement Action/Investigation: Unknown

Foreign Assistance: Unknown

Origin of the Proceeding: Unknown

Whistleblower: Unknown

Case Status: Resolved

Summary

Las Vegas Sands Corp. ("LVSC"), a corporation based and incorporated in Nevada, owned and operated resorts and casinos in the United States and Asia through a network of subsidiaries. The company’s common stock was registered with the SEC and traded on the New York Stock Exchange under the symbol “LVS.”

LVSC operated several subsidiaries in China. They included majority-owned Sands China Ltd., incorporated in the Cayman Islands and whose shares have traded on the Hong Kong Stock Exchange; wholly-owned Venetian Macao Ltd., an SCL subsidiary through which SCL operates in Macao; wholly-owned Venetian (Zhuhai Hengqin) Hotel Co. Ltd., a wholly foreign-owned entity (“WFOE”) established under Chinese law; wholly-owned Venetian (Zhuhai) Hotel Marketing Co. Ltd., a WFOE established under Chinese law; and Beijing Asia Travel Alliance Business Consulting Co., Ltd., a WFOE established under Chinese law.

From 2006 through at least 2011, LVSC transferred funds totaling more than $62 million to a consultant in China over a series of transactions that frequently lacked supporting documentation or appropriate authorization. Many of these transfers were made through LVSC's various subsidiaries noted above. Senior LVSC management knew that the environment posed a significant risk of bribery because they could not account for funds that had previously been transferred to the consultant, yet most of the above transfers occured despite this knowledge. Other transactions, including gifts and entertainment for foreign officials, employee and vendor expense reimbursements, and customer comps were also impacted by LVSC's lack of controls over how the consultant's money was used.

In an administrative proceeding on April 7, 2016, the SEC issued a cease and desist order against LVSC, to which the company agreed without admitting or denying the allegations therein. Under the terms of the order, the SEC ordered LVSC to cease and desist violating the books & records and internal controls provisions of the FCPA, ordered the company to pay a civil fine of $9 million, and ordered the company to hire an independent monitor for a term of two years. In agreeing to the settlement of the cease and desist proceedings, the SEC noted LVSC's significant cooperation and remediation.

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| Enforcement Action Dataset

Enforcement Action Dataset

Case Information

In the Matter of Las Vegas Sands Corp.

Case Information

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