Wynn Las Vegas to forfeit $130m over unlicensed money transfer schemes
The Southern District of California, which prosecuted the case, said the settlement with Wynn Las Vegas (WLV) is believed to be the largest forfeiture by a casino based on admissions of criminal wrongdoing. The total forfeit amounts to $130,131,645 (€117.3m/£99.0m).
According to a US attorney’s office press release, Wynn made a deal to avoid criminal prosecution. WLV admitted it illegally used unregistered money transmitting businesses to circumvent the conventional financial system.
Prosecutors laid out a series of illegal activities that WLV allowed that sometimes involved their employees. Among them: an opaque web of agents and payments used to skirt US and foreign laws in Latin America and China.
One independent agent conducted more than 200 transfers which were worth more than $17m.
“Casinos, like all businesses, will be held to account when they allow customers to evade US laws for the sake of profit,” said US 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.”
As part of this investigation, 15 other defendants previously admitted money laundering, unlicensed money transmitting, or other crimes. Penalties for those crimes are more than $7.5m.
How Wynn Las Vegas evaded US finance laws
Among the allegations brought by prosecutors, WLV regularly contracted with third-party agents acting as unlicensed money transmitting businesses. These agents recruited foreign gamblers. The independent agents transferred the gamblers’ funds through companies, bank accounts and other third-party nominees in Latin America and elsewhere. The funds were ultimately funnelled into a WLV-controlled bank account in the Southern District of California. At that point, the gamblers could use the funds.
Prosecutors also found evidence of WLV facilitating the unlicensed transfer of money through “Human Head” or “Human Hat” gambling. In this scheme, a person known as a “Human Head” bought chips and gambled as a proxy. The proxy gambled for someone who was unable or unwilling to conduct financial transactions or gamble under their own identity.
There was also evidence of WLV enabling transactions with individuals it knew to have been convicted of financial crimes. WLV failed to report transactions involving millions of dollars by an individual who, according to publicly available information, had spent six years in prison in China for conducting unauthorised international monetary transactions and violations of other financial laws.
In 2018, WLV facilitated financial transactions worth approximately $1.4m for an individual who was denied entry to the US.
“Federal laws that regulate the reporting of financial transactions are in place to detect and stop illegal activities,” Carissa Messick, special agent in charge for IRS-CI in Las Vegas said via the press release. “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.”