Las Vegas Sands Corp. said it resolved the U.S. Department of Justice's Foreign Corrupt Practices Act compliance investigation, launched in 2011, and entered into a three-year nonprosecution agreement with the DOJ.
The company agreed to pay a penalty of approximately $7 million and to uphold certain compliance, reporting and cooperation obligations.
The nonprosecution agreement is related to the failure of the company to implement proper internal accounting controls concerning payments to companies associated with a consultant in a region that is considered at high risk for corruption.
The company said it no longer employs or is affiliated with any of the individuals who were implicated in the case, a fact the DOJ took into account when setting forth the resolution. Also taken into account was the company's cooperation and thorough internal investigation.
Las Vegas Sands also agreed to submit copies of all reports from the independent compliance consultant retained in connection with the SEC's civil administrative settlement from April 2016. As part of that settlement, the company "neither admitted nor denied" allegations concerning internal controls and book provisions of the FCPA, and agreed to pay a $9 million penalty.
The company agreed to continue self-reporting to the DOJ for the remainder of the nonprosecution agreement's duration.