Wynn Las Vegas, the Las Vegas casino and subsidiary of Wynn Resorts, agreed Monday to forfeit $130,131,645 to settle criminal allegations that it conspired with unlicensed money transmitting businesses worldwide to transfer funds for the financial benefit of the casino.
Wynn Resorts’ settlement is potentially the largest forfeiture by a casino based on admissions of criminal wrongdoing
The settlement is believed to be the largest forfeiture by a casino based on admissions of criminal wrongdoing.
“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.”
A Non-Prosecution Agreement allows a company or individual to avoid criminal prosecution in exchange for meeting certain criteria. Under the agreement, Wynn Las Vegas (WLV) admitted that it illegally used unregistered money transmitting businesses to circumvent the system.
According to the news release from the U.S. Attorney’s Office for the Southern District of California, WLV regularly contracted with third-party independent agents acting as unlicensed money transmitting businesses to recruit foreign gamblers to WLV.
Independent agents transferred the gamblers’ funds through companies, bank accounts, etc.
For the gamblers to repay debts to WLV or have funds available to gamble at WLV, the independent agents transferred the gamblers’ funds through companies, bank accounts, and other third-party nominees in Latin America and elsewhere.
The funds were then transferred to a WLV-controlled bank account in the Southern District of California. Additionally, funds deposited into the WLV-controlled account were transferred into the WLV cage account.
WLV employees, with the knowledge of their supervisors, and working with the independent agents, later credited the WLV account of each individual patron. The transactions allowed foreign gamblers at WLV to evade foreign and U.S. laws governing monetary transfer and reporting.
WLV facilitated the unlicensed transfer of money through “Human Head” or “Human Hat” gambling
Per the news release, WLV also facilitated the unlicensed transfer of money through “Human Head” or “Human Hat” gambling, known in Mandarin as “人头” or “ren tou.”
In this scheme, a person known as a “Human Head” purchased chips at WLV and gambled at WLV as a proxy for another nearby individual.
The nearby person is unable or unwilling to conduct financial transactions or gamble under their own identity. This is usually because of the federal Bank Secrecy Act or Anti-Money Laundering (BSA/AML) laws.
However, the true patron would direct the Human Head’s gaming. WLV knowingly permitted this form of gambling without investigating the true patron’s funds and without reporting the activity.
WLV assisted the unlicensed transfer of money to and from China via “Flying Money” method
In another example, WLV facilitated the unlicensed transfer of money to and from China through a method known as “qian chen” or “Flying Money.”
A money processor, acting as an unlicensed money transmitter, collected U.S. dollars in cash from third parties in the U.S. Afterwards, the cash was delivered to a WLV patron who could not otherwise access cash in the U.S.
The patron then electronically transferred the equivalent value of foreign currency from the patron’s foreign bank account to a foreign bank account designated by the money processor.
The WLV patron paid the money processor a percentage of the value transferred. WLV knowingly allowed this form of gambling without examining the source of funds and without reporting the activity.
Wynn Resorts case was prosecuted by Assistant U.S. Attorneys Mark W. Pletcher and Carl F. Brooker IV.
Furthermore, WLV also facilitated the international transfer of money and conducted other financial transactions for WLV patrons. This activity should have triggered the filing of Suspicious Activity Reports.
“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,” said Carissa Messick, Special Agent in Charge for IRS-CI in Las Vegas.
“IRS Criminal Investigation is committed to following the money and enforcing these laws, wherever it leads.”
A total of 15 other defendants previously have admitted money laundering, unlicensed money transmitting, or other crimes. Associated criminal penalties resulted in over $7.5 million.
This case was prosecuted by Assistant U.S. Attorneys Mark W. Pletcher and Carl F. Brooker IV. Investigative agencies include the Homeland Security Investigations, IRS-Criminal Investigations, Las Vegas Financial Crimes Task Force, and Drug Enforcement Administration.
