Las Vegas casino Wynn Las Vegas (WLV), a subsidiary of Wynn Resorts, has forfeited $130m as part of a non-prosecution agreement with the US Department of Justice and the US Attorney’s Office for the Southern District of California over unlicensed money transmitting allegations.
According to a US Attorney’s Office statement, WLV forfeited $130,131,645 to “settle criminal allegations that it conspired with unlicensed money transmitting businesses worldwide to transfer funds for the financial benefit of the casino”.
It is also believed to be the largest forfeiture by a casino based on admissions of criminal wrongdoing.
US Attorney Tara McGrath commented: “Casinos, like all businesses, will be held to account when they allow customers to evade US laws for the sake of profit.
“Federal oversight seeks to prevent illegal funds from tainting legitimate businesses, ensuring that casinos offer a clean, thriving, and safe entertainment option.”
Through the non-prosecution agreement, which allows a company or individual to avoid criminal prosecution in exchange for meeting certain criteria, WLV “admitted that it illegally used unregistered money transmitting businesses to circumvent the conventional financial system”.
Wynn Resorts noted within an SEC filing that the agreement with DOJ and Attorney’s Office resolves “previously-disclosed investigation into various transactions at Wynn Las Vegas relating to certain patrons who reside or operate in foreign jurisdictions which were facilitated by former employees, agents and other third parties that were unlicensed money transmitting businesses, in violation of 18 U.S.C. § 1960”.
In addition to the $130m forfeited, Wynn Resorts agreed to “continue to make certain enhancements to its compliance program”. Subject to WLVs’ fulfilment of its agreement obligations, the DOJ will not bring “any criminal charges against Wynn Las Vegas concerning the subject matter of its investigation, subject to standard reservations of rights and certain reserved claims”.
According to the US Attorney’s Office, WLV “regularly contracted with third-party independent agents acting as unlicensed money transmitting businesses to recruit foreign gamblers” to the casino.
To make sure gamblers repaid their debts to WLV or had funds available to gamble, the independent agents “transferred the gamblers’ funds through companies, bank accounts, and other third-party nominees in Latin America and elsewhere, and ultimately into a WLV-controlled bank account in the Southern District of California”. These funds would then be transferred into a WLV cage account.
“WLV employees, with the knowledge of their supervisors, and working with the independent agents, eventually credited the WLV account of each individual patron,” noted the US Attorney’s Office.
“The convoluted transactions enabled foreign gamblers at WLV to evade foreign and US laws governing monetary transfer and reporting.”
In reaching the agreement resolution, Wynn Resorts’ SEC filing noted that the DOJ accounted for “the historical nature of the transactions at issue; Wynn Las Vegas’s cooperation with the DOJ’s multi-year investigation; that Wynn Las Vegas no longer employs or is affiliated with any of the individuals implicated in the transactions at issue; and Wynn Las Vegas’s extensive remedial measures, many of which were undertaken prior to the parties entering into the NPA”.
In addition, the SEC filing stated that “all prior US federal regulatory inquiries commenced in or about 2014 regarding compliance by Wynn Las Vegas with 18 U.S.C. § 1960 and the Bank Secrecy Act” have been resolved through the agreement.
Christopher Davis, acting special agent in charge for HSI San Diego, said: “Of the many unique authorities HSI is able to enforce, understanding and investigating complex financial crimes that lead to holding criminals accountable for their actions, is one that HSI does best.
“The success of this investigation is in part due to our partner agencies’ cooperation and dedication to seeing these long-term investigations through to bring justice to these companies and protect American financial institutions.”
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