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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into Las Vegas Sands' Activities in Unspecified Countries · Las Vegas Sands Corp.

Information & Summary

Investigation into Las Vegas Sands' Activities in Unspecified Countries

Related FCPA Matter:   Las Vegas Sands' Involvement in China from 2006 to 2011 Information

Information & Summary

Investigation Name:    Investigation into Las Vegas Sands' Activities in Unspecified Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:    Unknown

Whistleblower:    Unknown

Summary

Las Vegas Sands Corporation (LVSC) was a Nevada-based casino and resort company which operated through a network of subsidiaries, casinos, and gaming facilities in the United States, Macao, and Singapore. During the period of the alleged misconduct, LVSC's shares were publicly traded on the New York Stock Exchange, and the company therefore was an "issuer" within the meaning of the FCPA.

In its March 1, 2011 10-K filing, LVSC announced that it had received a subpoena from the SEC on February 9, 2011 that requested documents relating to the company's compliance with the FCPA. The company also announced that the Department of Justice was conducting a similar investigation.

After the company’s receipt of the subpoena, the LVSC Board of Directors delegated to the Audit Committee the authority to investigate the matters raised in the SEC subpoena and related DOJ inquiry. As part of the annual audit of the company’s financial statements, the Audit Committee advised the company and its independent accountants that it had reached certain preliminary findings, including that there were likely violations of the books and records and internal controls provisions of the FCPA and that in recent years, the company had improved its practices on both fronts.

On April 7, 2016, the SEC announced a comprehensive civil administrative settlement with LVSC in which the company neither admitted nor denied allegations related to the internal controls and books and records provisions of the FCPA. LVSC entered into a non-prosecution agreement (NPA) with the DOJ on January 19, 2017.

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