In a groundbreaking development, Wynn Las Vegas, a subsidiary of Wynn Resorts, Limited, announced today that it has agreed to forfeit a staggering $130,131,645 to settle criminal allegations. The settlement stems from claims that the renowned Las Vegas casino conspired with unlicensed money transmitting businesses across the globe to transfer funds for its own financial gain.

This groundbreaking settlement is believed to be the largest forfeiture ever imposed on a casino, underscored by the admission of criminal wrongdoing. U.S. Attorney Tara McGrath highlighted the importance of holding businesses accountable, stating that casinos, like any other enterprise, must face consequences when they enable customers to evade U.S. laws for the sake of profit.

The Non-Prosecution Agreement, which grants immunity from criminal charges in exchange for meeting specific requirements, compelled Wynn Las Vegas (WLV) to acknowledge its unlawful use of unregistered money transmitting entities to bypass traditional financial channels. One notable practice involved WLV collaborating with third-party independent agents acting as unlicensed money transmitting businesses to attract foreign gamblers to the casino.

To ensure that these gamblers could repay their debts or have funds available for betting, the independent agents would transfer their money through various companies, bank accounts, and other intermediaries in locations such as Latin America. Ultimately, the funds would find their way into a WLV-controlled account in the Southern District of California. From there, the funds were moved to the WLV cage account and credited to each individual patron's WLV account. This convoluted system enabled foreign gamblers to bypass monetary transfer and reporting regulations both in their home countries and the United States.

The case highlighted specific instances where WLV facilitated illegal money transfers. One such example involved Juan Carlos Palermo, who acted as an independent agent for WLV. Palermo operated numerous unlicensed money transmitting businesses in the U.S. and abroad, conducting over 200 transfers totaling more than $17.7 million on behalf of 50 foreign patrons.

Another illicit practice WLV employed was known as "Human Head" or "Human Hat" gambling, referred to as "人头" or "ren tou" in Mandarin. Under this scheme, a "Human Head" would gamble at WLV on behalf of a person who, due to legal restrictions, could not conduct financial transactions or gamble under their own identity. The true patron would direct the "Human Head's" gaming, while WLV turned a blind eye to the source of funds and neglected to report any suspicious activity.

Furthermore, WLV enabled unlicensed money transfers to and from China through a method called "qian chen" or "Flying Money." In this scenario, a money processor acting as an unlicensed money transmitting business would collect cash in U.S. dollars from third parties in the United States. The cash would then be delivered to a WLV patron who lacked access to cash in the U.S. The patron would subsequently transfer the equivalent value in foreign currency from their foreign bank account to a designated foreign bank account, paying a percentage of the transfer value to the money processor.

Several financial transactions facilitated by WLV should have triggered the filing of Suspicious Activity Reports but were allowed to proceed without scrutiny. Notably, WLV handled approximately $1.4 million in transactions for an individual who had previously been linked to proxy gambling and denied entry into the U.S. due to suspected associations with a criminal organization.

As part of the investigation, 15 other defendants have already pleaded guilty to charges relating to money laundering, unlicensed money transmitting, and other crimes. These individuals now face associated criminal penalties totaling over $7.5 million.

Law enforcement agencies emphasized the importance of enforcing financial regulations and preventing illegal activities. HSI San Diego's acting Special Agent in Charge, Christopher Davis, praised the successful collaboration between agencies and their commitment to upholding the integrity of American financial institutions.

With this groundbreaking settlement, Wynn Las Vegas has now cleared a significant hurdle on its path to rectify past wrongdoings. The forfeiture of $130,131,645 stands as a testament to the resolve of federal authorities in ensuring that casinos, just like any other business, do not evade U.S. laws for financial gain.