500.com Limited, an online sports lottery service provider in China, trades its stock on the NYSE.
In a 6-K filed on December 31, 2019, 500.com announced that the company’s board of directors had formed a Special Investigation Committee (“SIC”) to internally investigate alleged illegal money transfers and the role played by consultants in Japan following the arrest of one consultant (also a former director of the Company’s subsidiary in Japan) and two former consultants by the Tokyo District Public Prosecutors Office.
In a subsequent 6-K filed on January 16, 2020, 500.com disclosed that the SIC had retained King & Wood Mallesons LLP as legal advisor to assist with the internal investigation.
In a 6-K filed on September 28, 2020, 500.com said that despite not being a party to any legal proceeding in Japan, the company treated the allegations of illegal payments seriously. The company further disclosed that King & Wood Mallesons had completed a substantial portion of its investigation and presented a preliminary review to the SIC. The SIC, after considering KWM’s findings, did not identify any violation of the FCPA by the company in connection with the payments. 500.com also disclosed that the SIC was in the process of reviewing the Company’s compliance policies, procedures and internal controls based on the recommendations from KWM and that the company had updated and would continue to enhance its policies, procedures and internal controls as appropriate.
In a 6-K filed on October 7, 2020, 500.com announced that it had closed its internal investigation into the matter because it had not found "a sufficient basis to establish a violation of the [FCPA]."
Sometime in 2021, 500.com changed its name to BIT Mining Ltd.
Though the company made no further disclosures regarding the investigation after its October 7, 2020, 6-K filing, in a new filing on April 30, 2024, Bit Mining disclosed that indeed the DOJ and SEC had opened investigations into the company and that it was cooperating with both agencies. Additionally, the company disclosed that it was in discussions to resolve the investigations.
In its 20-F filed on May 15, 2024, BIT Mining disclosed that it had accrued $10 million in anticipation of settlement of the investigations.
On November 18, 2024, the DOJ and SEC announced settled enforcement actions against BIT Mining as well as the filing of charges against 500.com's former CEO Zhengming Pan.
