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ARTICLE · 06 FEBRUARY 2017

Red Notice Newsletter - January 2017

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The DOJ's enforcement action does not allege that Sands paid any bribes in violation of the FCPA, but that Sands failed to maintain an adequate system of internal accounting controls under the FCPA.

United StatesCompliance
Akin Gump Strauss Hauer & Feld LLP
Akin Gump Strauss Hauer & Feld LLP
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ANTICORRUPTION DEVELOPMENTS

Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action

On January 19, 2017, Las Vegas Sands Corporation ("Sands"), a Nevada-­based gaming and resort company, executed a nonprosecution agreement (NPA) with the Department of Justice (DOJ) resolving the government's investigation of alleged violations of the Foreign Corrupt Practices Act (FCPA).

Specifically, the DOJ's enforcement action alleges that, from 2006 through 2009, Sands engaged a consultant for the purpose of promoting the company's brand in the People's Republic of China and Macao, but that the consultant failed to provide sufficient documentation of the purpose for the payments demanded (as much as

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