Nine Months After SEC Settlement, Las Vegas Sands Pays $7M Penalty to Bring DOJ Investigation to a Close

Just one day before the recent change in administration, the DOJ announced its settlement with Las Vegas Sands Corp. to resolve FCPA charges stemming from payments made to a politically connected consultant doing business in China and Macao between 2006 and 2009. The deal is notable for the relatively small penalty involved given the behavior at issue and the cash flow of the company, as well as for the unusual lag between the resolution of the DOJ matter and an earlier one with the SEC over substantially the same facts. See “A Shady Consultant and Lackluster Accounting in China Wins Sands a $9 Million Penalty” (Apr. 20, 2016).

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