Wynn Las Vegas agrees to a $130 million settlement

The Southern District of California, which prosecuted the case, said the settlement with Wynn Las Vegas (WLV) is believed to be the largest monetary settlement by a casino for admitting criminal wrongdoing. The total amount of the settlement amounts to $130,131,645 (€117.3 million/£99.0 million).

According to a press release from the U.S. Attorney's Office, Wynn struck a deal to avoid criminal prosecution. WLV admitted that it illegally used unregistered money transfer companies to circumvent the conventional financial system.

Prosecutors revealed a range of illegal activities that WLV permitted and sometimes involved WLV employees, including a murky web of agents and payments that evaded U.S. and foreign laws in Latin America and China.

An independent agent made over 200 transfers valued at over $17 million.

“Casinos, like all businesses, will be held accountable when they allow their customers to circumvent U.S. laws for profit,” said U.S. Attorney Tara McGrath. “Federal oversight is designed to prevent illicit funds from harming legitimate businesses and to ensure that casinos provide a clean, thriving and safe entertainment option.”

As part of this investigation, 15 other defendants previously admitted to money laundering, illicit money transfers, or other crimes. The penalties for these crimes amount to more than $7.5 million.

How Wynn Las Vegas circumvented US financial laws

Among the prosecutors' allegations is that WLV regularly contracted with third-party agents who acted as unlicensed money transfer companies. These agents recruited foreign players. The independent agents transferred the players' funds through companies, bank accounts and other third parties in Latin America and elsewhere. The funds were ultimately transferred to a bank account controlled by WLV in the Southern District of California. At that point, the players could access the funds.

Prosecutors also found evidence that WLV facilitated the illicit transfer of funds through “human head” or “human hat” gambling. In this system, a person known as the “human head” would purchase chips and play as a proxy. The proxy would play for someone who was unable or unwilling to conduct financial transactions or gamble under their own identity.

There was also evidence that WLV facilitated transactions with individuals it knew had been convicted of financial crimes. WLV failed to report millions of dollars in transactions conducted by an individual who, according to publicly available information, served six years in prison in China for conducting unauthorized international money transactions and violating other financial laws.

In 2018, WLV facilitated financial transactions valued at approximately $1.4 million to an individual who had been denied entry to the United States.

“Federal laws governing the reporting of financial transactions are in place to detect and stop illegal activity,” Carissa Messick, special agent in charge of IRS-CI in Las Vegas, said in the release. “Intentionally evading the requirements of the Bank Secrecy Act is a form of money laundering. IRS Criminal Investigation is committed to following the money and enforcing these laws wherever it leads.”