Details of the Case
Wynn Las Vegas is paying the $130 to avoid prosecution. The agreement came this past Friday.
According to the United States Attorney’s Office in the Southern District of California, Wynn admitted that it illegally used “unregistered money transmitting business to circumvent the conventional financial system.” In doing so, the casino incurred financial gain.
Here’s how it worked:
Wynn Las Vegas contracted third-party independent agents acting as unlicensed money-transmitting businesses, and this recruited foreign gamblers.
If the gamblers needed to repay debts to Wynn or have funds available to gamble with, the independent agents transferred the money through bank accounts, companies, and other third parties in "Latin America and elsewhere."
From here, the funds landed in Wynn’s bank account in the Southern District of California. Then, those funds from the bank were transferred to the cage account, and the funds were eventually added to each person’s gambling account.
This allowed the foreign gamblers to get around foreign and United States monetary transfers and reporting.
Notable Examples
Juan Carlos Palermo acted as an independent agent for Wynn Las Vegas. He controlled multiple unlicensed money-transfer businesses in the United States and elsewhere. Palermo conducted over 200 transfers with bank accounts for Wynn or “associated entities.” These transactions were nearly $18 million.
Another example included a person dubbed “Human Head,” who purchased chips at Wynn and gambled at Wynn as a proxy for a person who was unable to gamble using their own identity due to the Bank Secrecy Act or Anti-Money Laundering laws. Wynn Las Vegas allowed this to happen and didn't scrutinize him or report the suspicious activity.
About 15 people have pleaded guilty, and about $7.5 million in penalties have been imposed.
Wynn Responds
Following this investigation, Wynn released a statement to the Las Vegas Review-Journal stating its commitment to operating with integrity.
“Wynn Resorts is committed to acting with the highest integrity and in full compliance with all laws and regulations governing our industry. The improper actions that are the subject of the settlement were undertaken by individuals with whom we severed ties years ago. The actions of these individuals, for which Wynn has accepted responsibility, date back many years and violated Wynn’s compliance policies and procedures. We are pleased that the company has now resolved this long-standing legal matter.”