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- Las Vegas Sands Pays 9 Million to Settle FCPA Allegations Relating to Over $62 Million in Payments
Las Vegas Sands Pays $9 Million to Settle FCPA Allegations Relating to Over $62 Million in Payments Made to Chinese Consultant
April 2016, Covington Alert
On April 7, 2016, Las Vegas Sands Corp. (“LVSC”) agreed to pay $9 million to settle allegations by the Securities and Exchange Commission (“SEC”) that LVSC, through its subsidiaries in China and Macao, violated the US Foreign Corrupt Practices Act (“FCPA”). The settlement resolves allegations that, from 2006 through at least 2011, LVSC and its subsidiaries violated the FCPA by failing to devise and maintain a system of internal accounting controls over its operations in China and Macao, resulting in more than $62 million being transferred to a Chinese consultant (the “Consultant”) who claimed to be a former Chinese government official. Only in 2007, after LVSC had made several payments to the Consultant, did it conduct due diligence on the Consultant and three of his business units. However, LVSC failed to conduct due diligence on at least seven other of the Consultant’s businesses to which LVSC transferred funds. The payments made to the Consultant were made for a series of transactions ostensibly designed to bring more customers to LVSC’s Macao-based casino as well as to boost its image in China.
November 14, 2018, Covington Alert
China recently amended its Criminal Procedure Law (CPL) to codify rules encouraging cooperation in government investigations, align with the new national supervision system, and introduce trials in absentia for certain crimes, including bribery and corruption.
November 8, 2018, Covington Alert
Last week, the U.S. Department of Justice announced a new “China Initiative.” According to the press release, the Initiative “reflects the Department’s strategic priority of countering Chinese national security threats and reinforces the President’s overall national security strategy.”
China: Government Reorganization and Trade War Suggest More Anti-Corruption Enforcement in China
March 29, 2018, Covington Alert
China’s biggest government reorganization in a generation, coinciding with rapidly escalating U.S.-China trade tensions, will impact many aspects of doing business in China, including an uptick in anti-corruption enforcement.