Wynn Las Vegas (WLV) has agreed to pay what is believed to be the largest casino forfeiture on record—US$130.1 million (£99m)—to avoid criminal prosecution for “illegally conspiring with unlicensed money transmitting businesses worldwide to transfer funds for the financial benefit of the casino” through convoluted schemes, such as the Human Head and Flying Money methods.
In a press release penned by the U.S. Attorney’s Office for the Southern District of California, prosecutors detailed the findings of a ten-year investigation into WLV, making the storied casino the latest name to set regulatory tongues wagging.
As part of the Non-Prosecution Agreement (NPA) between the U.S. Attorney’s Office and WLV, the company admitted its criminal wrongdoing in using third-party payment businesses to “evade foreign and U.S. laws governing monetary transfer and reporting.”
During the investigation, agents found multiple methods had been used to transfer millions of dollars of money between WLV and consumers outside the U.S. without proper checks.
These included complex transfers between WLV-controlled accounts, the casino cage, and WLV patron accounts, as well as more wildly named schemes.
Human Head
The Human Head scheme, for example, used a proxy, aka the “human head,” to purchase chips and gamble for another who could not wager under their own identity due to the federal Bank Secrecy Act or Anti-Money Laundering laws.
The genuine customer was nearby, directing the human head on how to bet. According to the NPA, “WLV knowingly allowed this form of gambling without scrutinising the true patron’s funds and without reporting the suspicious activity.”
Flying Money
A second scheme, Flying Money, involved patrons who couldn’t legally transfer money into the USA. These patrons would deposit money into a foreign account—owned by the money transfer business—and then receive it in cash in the U.S. As payment, the money transfer company took a cut.
Wynning Response
WLV has said that the findings did not amount to money laundering and that the company has already cut all ties with the contracted money-moving businesses and implicated WLV individuals, which the NPA confirmed.
Wynn Resorts’ official statement said, “The improper actions that are the subject of the settlement were undertaken by individuals with whom we severed ties years ago.
“The actions of these individuals, for which Wynn has accepted responsibility, date back many years and violated Wynn’s compliance policies and procedures.”
The statement refers to the tainted legacy of Las Vegas mogul Steve Wynn, who stepped down as CEO in 2018.
Happy to put the past behind them, the statement continued, “Beginning in 2018, we took decisive action to transform our workplace environment and governance and begin a new chapter for Wynn. These settlements are the final milestone in that process, as we put legacy issues fully behind us and focus on our future.”
Wynn Resorts must pay the NPA in two instalments, and to finance this, it has raised US$800m through a private debt offering.
