Wynn Las Vegas Forfeits $130M to Settle Financial Offenses Allegations

The US Department of Justice (DOJ) announced that Wynn Las Vegas, Wynn Resorts’ Vegas-based subsidiary, has agreed to pay over $130 million to settle claims that it worked with unlicensed money transfer companies. According to the DOJ, this is the largest such forfeiture by a casino company yet.

The Company Allegedly Conspired with Illegal Businesses

Wynn Las Vegas, for context, was accused of conspiring with unlicensed businesses across the world that transferred funds for the financial benefit of the company. As part of a non-prosecution agreement, Wynn Las Vegas admitted that it committed such offenses to “circumvent the conventional financial system.”

According to the announcement, Wynn admitted to doing business with third-party independent agents who acted as unlicensed money-transmitting businesses to “recruit foreign gamblers.” In order to allow these players to repay debts or charge their accounts to gamble, these agents transferred funds through services and third parties based in Latin America and elsewhere.

The money would ultimately end up in a Wynn Las Vegas-controlled bank account in the Southern District of California and would be transferred into the cage account. This complex system allowed foreign gamblers to avoid money transfer and reporting-related laws.

The DOJ Cited Several Examples

The DOJ cited one example, which involved the independent agent Juan Carlos Palermo. He operated and controlled multiple unlicensed money-transmitting businesses in the US and abroad and conducted over 200 transfers with bank accounts controlled by Wynn Las Vegas or its associated entities. The transactions were made on behalf of more than 50 foreign players and exceeded $17.7 million.

Another method involved what the DOJ called “human head” or “human hat” gambling whereby someone would act as a proxy for another person who, because of the law, was unable or unwilling to gamble under their own identity.

A third method included what the DOJ called “flying money.” This would see a money processor act as an unlicensed money-transmitting business and collect US dollars in cash from third parties in the US before delivering it to a patron who would not otherwise have access to cash in the country. The patron would then electronically transfer the equivalent value of foreign currency from their foreign bank account to a foreign bank account designated by the money processor.

According to the DOJ, Wynn admitted that it allowed such a form of gambling without checking the source of funds or flagging the suspicious activity. Speaking of that, the company conducted other transactions that should have triggered the filing of suspicious activity reports. Some of the transactions involved millions of dollars. A few were related to an individual who had spent six years in prison in China for financial fraud.

Experts Highlighted the Importance of Upholding the Rules

US Attorney Tara McGrath noted that casinos should be held to account when they evade or facilitate evasion of US laws for the sake of profit.

Christopher Davis, acting special agent in charge for HSI San Diego, added that financial fraud can be extremely complex. He attributed the success of the latest investigation to the immense contributions of HSI’s partner agencies.

Carissa Messick, special agent in charge for IRS-CI in Las Vegas also weighed in, saying that federal laws are in place to identify and prevent such illegal activities. She critiqued the deliberate evasion of these laws, saying that it constitutes a criminal offense.

Last but not least, DEA special agent in charge Brian Clark said that law enforcement must work hard to ensure that the financial system is not being exploited or circumvented.

The DOJ pointed out that the investigation also involved 15 other defendants who have previously admitted to money laundering, unlicensed money transmitting, or other crimes.