Legal Alert - Sands' Casinos Report of “Possible” FCPA Violations Will Draw Scrutiny to the Gaming Industry
by Brett W. Johnson and Heidi McNeil Staudenmaier
On Friday, March 1, 2013, the parent company of the Las Vegas Sands Corp. (Sands), reported in a filing to the Securities and Exchange Commission (SEC) that the company may have violated the “books and records and internal control provisions” of the Foreign Corrupt Practices Act (FCPA). In a subsequent release, Sands reiterated that its agents did not bribe foreign officials and that it just did not properly track expenditures as required by the FCPA. Media reports have linked the possible SEC and Department of Justice (DOJ) investigations to a wrongful termination lawsuit by a former employee. Regardless, the Sands' disclosure and related government investigation will have ripple effects throughout the international gaming industry. The Sands' report provides an all too familiar case study in regard to FCPA and international trade law compliance.