On April 7, 2016, the SEC settled FCPA allegations with Las Vegas Sands, the Nevada-based operators 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.”