Las Vegas Sands will pay a $6.96 million criminal penalty and enter into a non prosecution agreement to resolve the government’s investigation into violations of the Foreign Corrupt Practices Act (FCPA) in connection with business transactions in the People’s Republic of China (PRC) and Macao.
According to admissions by Sands made in connection with the resolution, certain Sands executives knowingly and willfully failed to implement a system of internal accounting controls to adequately ensure the legitimacy of payments to a business consultant who assisted Sands in promoting its brand in Macao and the PRC, and to prevent the false recording of those payments in its books and records.
In total, from 2006 through 2009, Sands paid about $5.8 million to the business consultant without any discernable legitimate business purpose, it admitted.
— source corporatecrimereporter.com