- Money Laundering Laws
- Malaysia Money Laundering Scams
- How To Spot Money Laundering
- 3 Steps Of Money Laundering
- Money Laundering Thru Casinos
- Money Laundering Through Casinos
(Bloomberg Businessweek) -- When Chinese businessman Wang Xi first gambled at Sheldon Adelson’s Marina Bay Sands casino in Singapore, he hit the jackpot, winning $3.7 million. After more wins in later trips, his luck turned sour and he racked up millions in losses. After one particularly tough day in the high-roller room, he threw a water glass at a staff member, and brought his father in to review his accounts, according to documents seen by Bloomberg.
Marina Bay Sands recently paid a VIP S$9.1m (US$6.8m) to settle a lawsuit over fund transfers. LVS has demonstrated a new Asia focus, selling its properties in Las Vegas for US$6.25bn. Following claims of anti-money laundering failings, Las Vegas Sands has launched an internal probe into its Marina Bay Sands casino in Singapore. Adelson’s Singapore Casino Hires Law Firm to Probe $1 Billion in Transfers17 Sep 2020. Las Vegas Sands Corp.’s Singapore casino has hired a law firm to conduct a new investigation into employee transfers of more than $1 billion in gamblers’ money to third parties, according to people familiar with the matter. (Mar 29): Las Vegas Sands Corp. Set up a special committee to look into potential breaches of anti-money laundering procedures at its Singapore casino, which has already been the target of probes by U.S. Officials and local police.The committee of three independent board members is reviewing money transfers among high-rollers and third parties at Marina Bay Sands, as well as any possible.
The family probe yielded a windfall of a different sort. In a 2019 lawsuit, Wang claimed the Marina Bay Sands had transferred S$9.1 million ($6.9 million) of his money to third parties in 22 separate transactions without his authorization. The forms for wiring his money weren’t signed by him and appear to have been forged, the originals destroyed, according to the lawsuit. The casino settled the case in June and repaid Wang, without admitting wrongdoing.
Wang’s suit and similar ones shined a light on the murky world of third-party transfers that casinos and gamblers use to settle accounts. Since gambling is illegal on the mainland, so-called junket operators have stepped in to facilitate it, especially in Macau, a favorite for Chinese gamblers. It isn’t easy for Chinese citizens to wire money abroad, so in addition to booking five-star hotels and private jets, junket operators often act as an informal bank, providing gamblers with credit, stashing winnings, and settling losses with casinos and other bettors.
In Singapore, Marina Bay Sands prohibits the use of these junkets, concerned that the untraceable flow of money opens the door to money laundering. Instead, the casino allows patrons to transfer money to other gamblers they know, covering losses or sharing winnings. Think of it as an informal lending club among millionaires. For the casino, the so-called Letters of Authorization seemed like a way to avoid the junkets while still facilitating gambling by the “whales” who generate so much profit for its business.
Third-party transfers, which are legal, have been used by the casino for years, according to people familiar with the operations. An internal investigation showed 3,419 transfers worth S$1.64 billion were shuffled among gamblers by casino employees from October 2010 through December 2018.
A problem for Marina Bay is that several employees appear to have highjacked the process from about 2013 to 2018. They would get the patrons to sign a blank authorization form to get things started, then fill in the amount of the transfer and other details for subsequent wires. At times they’d use photocopies of the same document on multiple occasions to expedite the moves, copy signatures if needed, and destroy the originals after the funds were sent, the people say.
Marina Bay management was largely unaware of the transfer problem until 2018, according to a former compliance executive who was interviewed as part of an internal investigation. When the executive brought up the issue and tried to tackle it, the operations and legal teams urged him to back off. Later, his contract was not renewed, the official told the law firm conducting the investigation.
Marina Bay Sands says it’s cut back on third-party transfers and tightened security over their usage. Documents seen by Bloomberg show the amount of transfers dropped to just six in 2018 from a peak of 1,011 in 2014.
In a June letter to Singapore’s casino regulator, Marina Bay Sands said it took steps in 2018 to increase its scrutiny of all transfers, and further beefed up the measures this year. These steps included ensuring that all transfer letters had fresh “wet ink” signatures and that staff received a verbal confirmation from the patron before moving any funds.
Third-party transfers “are subject to enhanced due diligence checks which will include screening of the patron and third-party for junket affiliation and declaration of the relationship between the patrons and the reasons for the patron making the third-party payment,” the casino wrote. “MBS remains focused on having highest-level best practices of governance, compliance and internal controls that are continuously improved.”
Unauthorized transfers weren’t the casino’s only problem before they were dealt with starting in 2018. While Marina Bay Sands’ policy is not to deal with junkets, some rogue employees were working with these operators to attract Chinese gamblers, according to documents reviewed by Bloomberg. There have been cases in which Chinese clients said they settled their gambling accounts through the junkets, which didn’t pass along the money to the casino, resulting in uncollected debts and subsequent legal action.
For example, in 2018, Marina Bay Sands sued a customer named Luo Shandong, seeking repayment of S$3.5 million in gambling debts and interest, according to court documents. Luo says he paid the money through Tian Du Gaming Promotion Co., a junket company that operated in the casino’s VIP lounge. He says Tian Du provided him with credit and collected repayments on behalf of Marina Bay Sands. The casino denied the connection.
A Sands collections executive says it was common for patrons to inform the casino that they had paid a third party. The executive would then be obliged to inform them that they’d paid the wrong party, according to the internal investigation.
The whales are the big moneymakers for casinos, and some employees say they needed to work with junkets to attract them. One former marketing executive says that when Sands Singapore opened, they needed to call in the junkets because of a lack of local contacts.
While it’s not clear how much money the unauthorized transfers and unpaid debts cost Marina Bay Sands, from 2013 through March 2020 the casino wrote off $717 million from 928 accounts, according to an internal document seen by Bloomberg. A former Sands executive says typical losses for a casino that size are $20 million to $30 million a year. The peak write-offs were in 2015 to 2017, the years immediately following the biggest transfers, while 67% of the dollar value was tied to Chinese clients, the document shows.
The casino denies the transfers contributed to the writedowns.
“Third-party transfers are part of the ordinary course of business within our industry. We remain confident that the processes we have in place relating to such transfers are secure, with appropriate levels of authorization and controls,” the casino said in a statement to Bloomberg.
Money Laundering Laws
“By the same token, because patrons sometimes finance their play at our property by borrowing funds which they then fail to repay, write-downs are not uncommon in our business,” the casino added. “Any suggestion that write-downs are commonly the result of third-party transfers, or that write-downs at our property exceed industry norms, is inaccurate.”
Marina Bay Sands remains under scrutiny. The U.S. Department of Justice is reviewing whether the casino breached money laundering controls in its treatment of high rollers and retaliated against whistleblowers who are current or former employees, according to a January subpoena issued to a former chief compliance officer at the casino.
The U.S. attorney’s office in Las Vegas declined to comment about the Justice Department probe.
“Marina Bay Sands is committed to running a best-in-class compliance program and has dedicated significant resources to developing the robust program currently in place,” the casino said in the statement to Bloomberg. “As part of that program, we evaluate our internal policies on a regular basis and make changes where our compliance and business goals are not being achieved or our business values are not being met.”
Singapore’s police force is also probing the transfers in the wake of the Wang case, and the casino has hired another law firm—Davinder Singh Chambers LLC—to conduct an investigation into the employee wires.
The Casino Regulatory Authority has completed its investigations, and there are no ongoing reviews, a spokesman for the agency of says.
Malaysia Money Laundering Scams
Singapore had early reservations about casinos. Prime Minister Lee Hsien Loong was worried that gambling would bring “undesirable activities”—money laundering and organized crime, namely—to his island off the tip of Malaysia. Billionaire Adelson, the 23rd-richest person in the U.S., accentuated the positive after Singapore ended its casino ban: thousands of jobs, billions of dollars in tourism revenue, and a chance for Singapore to shed its reputation as one of the sleepier places in Asia.
A decade later, it appears both sides may have been right. Marina Bay Sands is a runaway success. Covid-19 notwithstanding, it’s one of the most profitable casinos in the world based on margins, accounting for a third of earnings at Adelson’s Las Vegas Sands Corp.
How To Spot Money Laundering
Asian bettors have flocked to the 600 game tables and 1,500 slot machines spread over four cavernous, smoke-filled floors, with gold-trimmed fixtures that are a cut above the more pedestrian halls of Macau. While patrons in the upper-floor Ruby salons enjoy unlimited food and drink, the real money flows through the 36 private Paiza rooms that attract high rollers with gambling budgets as high as $50 million, according to the people familiar with the operations.
These big spenders, most of them from China, wager at least S$10,000 a hand and receive red-carpet treatment, escorted in Mercedes-Benz S-Class sedans to a discreet entrance. In these gilded rooms they can bet as much as S$1.5 million at baccarat, the preferred card game in Asia that relies more on luck than on skill.
There’s so much money flowing through the halls that one of the gamblers stores $17 million worth of wine in the cellars at the casino’s Imperial Palace restaurant, a person familiar says. Away from the gaming tables, the Moshe Safdie-designed complex of three curved hotel towers linked by a boat-shaped canopy with an infinity pool has become the city’s tourism icon, featured in the Hollywood hit Crazy Rich Asians.
And while Singaporeans are welcome to shop in the complex’s mall, explore the ArtScience Museum on-site, and sip whiskies at the rooftop Ce La Vi bar, they’re discouraged from actually gambling. They must pay a S$150 fee just to enter the casino, euphemistically known as an “integrated resort,” to accentuate the family fun. Visitors are hard-pressed to find a “casino” sign anywhere.
3 Steps Of Money Laundering
Adelson is showing no signs of pulling back. In fact, he’s doubling down in Asia while exploring a sale of his Las Vegas properties, people familiar say. He’s already committed to a $3.3 billion expansion of Marina Bay Sands, which will include a fourth hotel tower, a 15,000-seat arena, and a convention center.
“History has shown us that these businesses are to an extent too big to fail,” says Ben Lee, the Macau-based managing partner at IGamiX. Las Vegas Sands “already had a couple of run-ins with the DOJ, which resulted in minor fines, a slap on the wrist, and then business as usual.” —With Tom Schoenberg and Daniela Wei
Money Laundering Thru Casinos
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Money Laundering Through Casinos
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