In a landmark decision, Wynn Las Vegas, the renowned Las Vegas casino and a subsidiary of Wynn Resorts, Limited, has agreed to forfeit a staggering $130.1 million to resolve criminal allegations related to illicit financial practices. This settlement, described as the largest forfeiture by a casino based on admissions of criminal wrongdoing, highlights the significant legal and financial repercussions that can arise from non-compliance with U.S. financial regulations.
The Allegations Against Wynn Las Vegas
The core of the allegations against Wynn Las Vegas centers on its involvement with unlicensed money-transmitting businesses to facilitate illegal fund transfers. According to federal authorities, Wynn Las Vegas conspired with these businesses to circumvent conventional financial systems, enabling foreign gamblers to bypass U.S. laws and regulations.
One of the main strategies used by Wynn Las Vegas involved utilizing unregistered money-transmitting businesses to attract foreign gamblers. These agents transferred funds through a complex network of companies, bank accounts, and third-party nominees, ultimately funneling the money into a Wynn Las Vegas-controlled account in Southern California. From there, the funds were moved into the casino’s cage account and credited to the accounts of individual patrons. This method allowed foreign patrons to gamble at Wynn Las Vegas without proper scrutiny or adherence to reporting requirements.
Illegal Practices and Evasion Techniques
The investigation uncovered several illicit practices employed by Wynn Las Vegas to facilitate these illegal transactions. One prominent tactic included the practice of “Human Head” or “Human Hat” gambling. In this practice, an intermediary, known as a “Human Head,” would gamble on behalf of another individual who was either unable or unwilling to use their own identity for financial transactions. This practice allowed the true patron to remain anonymous while evading regulatory scrutiny.
Another tactic, known as “qian chen” or “Flying Money,” involved unlicensed money processors gathering cash in the U.S. and transferring it to a Wynn Las Vegas patron. The patron would subsequently transfer an equivalent sum of foreign currency to a specified foreign bank account. This process, which included a commission fee for the money processor, further enabled patrons to bypass legal financial channels.
Additionally, Wynn Las Vegas facilitated transactions that should have triggered Suspicious Activity Reports (SARs), a requirement under the Bank Secrecy Act and Anti-Money Laundering laws. The casino failed to report several large transactions involving individuals with known criminal ties or questionable financial histories, further complicating the legal landscape surrounding its operations.
Federal Response and Consequences
The settlement with Wynn Las Vegas highlights the importance of compliance with financial regulations and the lengths to which federal authorities will go to ensure transparency in the financial system. U.S. Attorney Tara McGrath emphasized that businesses, including casinos, must adhere to laws designed to prevent financial misconduct and protect the integrity of the financial system.
Christopher Davis, acting special agent in charge for Homeland Security Investigations (HSI) San Diego, highlighted the success of the investigation, attributing it to the cooperation of various law enforcement agencies. Carissa Messick, Special Agent in Charge for IRS Criminal Investigation (IRS-CI) in Las Vegas, echoed this sentiment, noting the commitment to enforcing financial laws and preventing money laundering.
Moreover, DEA Special Agent in Charge Brian Clark stressed the importance of collective efforts by law enforcement to uphold the integrity of financial systems and prevent circumvention of regulations.
Broader Implications for Wynn Las Vegas
The forfeiture represents not only a significant financial penalty but also a pivotal moment in the regulatory oversight of the casino industry. It serves as a reminder to other businesses about the potential consequences of engaging in or enabling illegal financial practices. With $130.1 million forfeited, Wynn Las Vegas is held accountable for its actions, and the case sets a precedent for future enforcement actions against similar misconduct.
In addition to the forfeiture, the investigation has led to criminal penalties for 15 other defendants involved in related activities, totaling over $7.5 million. This extensive legal action emphasizes the seriousness of the offenses and the rigorous enforcement of financial regulations.
The historic forfeiture by Wynn Las Vegas marks a significant development in the ongoing efforts to uphold financial integrity and regulatory compliance in the casino industry. By addressing these serious allegations and imposing substantial penalties, federal authorities reaffirm their commitment to maintaining a transparent and lawful financial environment. The case serves as a cautionary tale for businesses and highlights the crucial role of regulatory oversight in safeguarding the financial system.
