Defendant Name:
Las Vegas Sands Corp.
Defendant Type:
Public Company
SIC Code:
7011
CUSIP:
51783410
Document Reference:
34-77555
Document Details
Legal Case Name
In the Matter of Las Vegas Sands Corp.
Document Name
Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order
Document Date
07-Apr-2016
Document Format
Administrative Proceeding
Allegation Type
Foreign Corrupt Practices Act
Document Summary
On April 7, 2016, the SEC instituted settled cease-and-desist proceedings against Las Vegas Sands Corp. According to the SEC: "This matter concerns the failure of LVSC to devise and maintain a reasonable system of internal accounting controls over its operations in the People's Republic of China ('PRC' or 'China') and the Macao Special Administrative Region of the People's Republic of China ('Macao') from 2006 through at least 2011. As a result, funds totaling more than $62 million were transferred to a consultant in China over a series of transactions under circumstances that frequently lacked supporting documentation or appropriate authorization. Moreover, most of the transfers occurred despite knowledge by senior LVSC management that they could not account for significant funds previously transferred to the consultant in an environment where significant bribery risks were present. This lack of controls impacted other transactions, such as gifts and entertainment for foreign officials, employee and vendor expense reimbursements, and customer comps. The company also kept inaccurate books and records." The SEC also stated that: "Respondent acknowledges the the Commission is not imposing a civil penalty in excess of $9,000,000 based upon its cooperation in a Commission investigation and related enforcement action."
Disgorgement & Penalty Information
Resolutions
Cease and Desist Order
Compliance Related Independent Consultant
Other Compliance Related Undertaking
Compliance-related undertakings
Cooperation Before the Resolution
Remedial Acts or Efforts Before the Resolution
Monetary Penalties:
Civil Penalty
Individual:
$9,000,000.00
Shared:
