Wynn Resorts Forfeits £99 million To Avoid Prosecution
Wynn Resorts has agreed to forfeit £99 million ($130 million) to the Department of Justice, to head off a full criminal investigation for unlicenced betting. That’s the largest forfeiture based on criminal allegations in casino history.
The allegations centred around Wynn Las Vegas Resort working with unlicenced money transfer services around the world. This is s non-prosecution settlement, so technically it’s not a fine or definitive proof of money laundering.
But accepting the forfeiture was essentially an admission that Wynn Las Vegas had used unregistered money transfer businesses and committed a vast number of offences.
Essentially Wynn Resorts has agreed to surrender the funds from problematic transfers, but had it not done so then potentially damaging charges were the next steps.
In a statement, the DOJ said: “Casinos, like all businesses, will be held to account when they allow customers to evade U.S. laws for the sake of profit,” said U.S. Attorney Tara McGrath. “Federal oversight seeks to prevent illegal funds from tainting legitimate businesses, ensuring that casinos offer a clean, thriving, and safe entertainment option.”
The DOJ was clearly confident of securing a conviction and had a mass of very specific evidence to present. The investigation into Wynn Resorts stretched back for more than a decade and the DOJ outlined several ongoing and highly illegal practices that the Wynn Resort Las Vegas was routinely engaged in.
According to the DOJ, WLV regularly used third-party independents to recruit foreign gamblers. Those agents transferred the individual gamblers’ funds through companies, bank accounts and nominees in Latin America to funnel money to a WLV bank account in California. With Wynn employees’ full knowledge, the funds were then transferred into the company cage account and credited to the individual gamblers.
These transactions could only be for the purpose of helping foreign gamblers evade restrictions and reporting laws.
Juan Carlos Palermo was one of many foreign agents. He conducted more than 200 transactions with WLV accounts, controlling more than £13.5 million ($17.7 million) for 50 gamblers. The DOJ also revealed that Wynn Resorts allowed ‘Human Head’ gambling practices, essentially proxies gambling on behalf of foreign individuals.
In 2018, WLV facilitated the transfer of $1.4 million for an individual who had been linked to proxy gambling two years earlier and denied entry to the United States due to suspected links with a criminal organisation. In another incident, WLV did not report transactions worth millions of dollars for an individual who had spent six years in prison in China for conducting unauthorized international monetary transactions and violations of other financial laws.
This is a damning list of potential charges and it’s interesting that the DOJ chose to publicise the individual details of the case so clearly. The investigation went on for 10 years and the Department of Homeland Security, Drug Enforcement Agency and Internal Revenue Service Criminal Investigation department all collaborated on this lengthy investigation.
“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,” said Christopher Davis, acting special agent in charge for HSI San Diego. “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.”
Carissa Messick, Special Agent in Charge for IRS-CI in Las Vegas, added: “Federal laws that regulate the reporting of financial transactions are in place to detect and stop illegal activities. Deliberately avoiding Bank Secrecy Act requirements is a form of money laundering. IRS Criminal Investigation is committed to following the money and enforcing these laws, wherever it leads.”
15 defendants have been successfully prosecuted for money laundering, unlicensed money transmitting and a series of other crimes in the course of this investigation.
