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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.

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