Navigating Forex Trading Regulations: Las Vegas Law Attorney’s Expertise – BRIGHT LIGHTS, CITY IN ACTION: The Palazzo Las Vegas (L), The Venetian Las Vegas and other hotels lit up the sky in a golden hue. In recent years, casinos have attracted high-profile players from China. /David Becker

After 9/11, when cash transactions were more tightly controlled, Las Vegas casinos stemmed the flow of money in part by luring wealthy Chinese gamblers. But the case involving the Sands casino shows that players and closed-room loans are often part of the game.

Navigating Forex Trading Regulations: Las Vegas Law Attorney’s Expertise

Navigating Forex Trading Regulations: Las Vegas Law Attorney's Expertise

LAS VEGAS — When Las Vegas Sands Corp. tried to collect gambling debts last year, two women owed $6.4 million. USD lost in a few disastrous days of baccarat.

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But when Sands asked prosecutors to file criminal charges against Xiufei Yang, 59, and Meie Sun, 52, for bad debt, lawyers for both women rejected the surprise charges.

Yang and Sun were not big gamblers, their attorneys said in court documents. They were local housekeepers hired by the Sands staff to take out millions of dollars in credit on their behalf and sit next to players as they gambled with borrowed chips. Back then, real gamblers could play paperless at the company’s Venetian and Palazzo casinos on the Las Vegas Strip.

The women’s attorneys, Jeffrey Setness of the law firm of Fabian VanCott and Kevin Rosenberg of Lowenstein & Weatherwax LLP, argue that Sands may have violated federal anti-money laundering rules that prohibit casinos from helping players withhold their names.

Lawyers describe the women as the bottom rung of a network of hosts and handlers who court wealthy Chinese gamblers and sometimes help them gamble anonymously.

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Because all parties knew the debts were fictitious, lawyers argued Sun and Yang’s markers — the IOUs players sign to receive credit from casinos — should be invalid. The women were the “real victim” here, the attorneys said, and the court should reject any effort to convict them of activities that “Las Vegas Sands initiated and fully contributed to.”

Sands spokesman Ron Reese called the allegations a “smokescreen” to distract from the women’s debts. The company has “no clear evidence” that the women were recruited by Sands employees, he said.

The case, which until now has not been reported in the media, opens a window into how multimillion-dollar bets flowed freely on the gaming tables at Las Vegas casinos in the post-9/11 era, when large cash transactions were subject to tighter US regulatory controls. .

Navigating Forex Trading Regulations: Las Vegas Law Attorney's Expertise

Las Vegas industry executives, casino floor workers and independent agents said in interviews that some casinos that cater to high-net-worth Chinese players often use hotpots.

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The episode also shows how important Chinese money has become to America’s gambling capital at a time when Macau has eclipsed Las Vegas as the world’s biggest gambling hub. In recent years, Vegas has tried to lure wealthy mainland Chinese gamblers, often to the baccarat tables, by filling the casinos’ exclusive VIP rooms with Macau decor.

The effort paid off. Casino winnings at baccarat have nearly doubled to $1.3 billion over the past decade, as overall gambling revenue on the Strip has stagnated. USD accounts for 40% of all games, state records show.

Asians make up as much as 90% of baccarat players in Las Vegas, and the majority are Chinese, said Steve Rosen, president of Marketings, a casino consulting firm. Asian players now make up about 75% of Las Vegas players, he said.

BACCARAT LURE: Experts say Asians account for as much as 90% of all Las Vegas baccarat games. Baccarat advertisement at The Venetian Las Vegas. /David Becker

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“There may be a reluctance in some industries to comply.” Treasurer Jennifer Shasky Calvery in 2013. at a gaming convention

But China’s revenue stream has a downside: most of these games are played on credit because the amounts are so high. According to the company’s financial filings, two-thirds of all table bets at Sands Las Vegas properties are placed on home loans. And gambling debt is not recognized by Chinese courts as valid, so it is largely unenforceable in China, said Andrew Klebanow, a casino specialist at Global Market Advisors.

Gamblers use the funds to get extra lines of credit after bad losing streaks or because they don’t want to disclose the source of the funds in casino records, according to six industry veterans with experience serving high-profile Chinese players.

Navigating Forex Trading Regulations: Las Vegas Law Attorney's Expertise

Four people with extensive experience at the Sands’ Venetian and Palazzo casinos say the practice is well known to managers and hosts who specialize in attracting this clientele.

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Unlike the crowded main betting floors of the Venetian and Palazzo, the high stakes rooms are intimate, often seating one or two tables of players. The shills who signed for the credit sat next to the gamblers. According to former employees, little effort was made to cover up the shady deals. “It was obvious,” said one.

The Sands says that even if Yang and Sun were shills, it was irrelevant: “At the end of the day, those people signed the credit in their name and that debt should be collected,” said spokesman Reese.

In a subsequent statement, Reese said: “If credible evidence is provided that an employee or employees contributed, we will immediately take the appropriate action required by our policy. However, even such a scenario, in which an employee of the company was involved, still does not eliminate the debt.

U.S. law enforcement officials are increasingly worried that Las Vegas could become a target for money launderers because of inadequate customer screening and large cash transactions. This is a violation of federal anti-money laundering laws designed to help gamblers avoid financial reporting requirements and remain anonymous.

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“I fear that there may be a culture in some industries of reluctance to comply with the bare minimum, if not less,” said Jennifer Shasky Calvery, then-director of the U.S. Treasury’s Financial Crimes Enforcement Network, FinCEN, during a 2013 hearing. gambling in Las Vegas. industry convention.

Such concerns have led to a crackdown on casinos and fines for alleged anti-money laundering violations.

For example, Sands in 2013 paid 47 million USD to end the US Department of Justice investigation after it emerged that suspected Chinese-Mexican drug trafficker Zhenli Ye Gon lost more than $84 million in a Venice store.

Navigating Forex Trading Regulations: Las Vegas Law Attorney's Expertise

U.S. authorities said Sands continued to cooperate with Ye Gon even as he told casino employees he was moving money in stages to avoid government scrutiny, according to a statement of facts Sands agreed to as part of a plea deal with the Justice Department.

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Ye Gon is currently in a US prison in Virginia awaiting extradition to Mexico on drug charges. Ye Gon’s lawyer, Gregory Smith, said his client ran a legitimate pharmaceutical company and was not a drug dealer.

More recently, federal authorities have been scrutinizing US casino practices that allow gamblers to gamble without leaving a paper trail.

Last year, for example, FinCEN allocated $8 million to Caesars Entertainment Corp casino fined $100,000 for poor anti-money laundering controls at its VIP lounges. Caesars Palace admitted in a civil settlement with the Treasury Department that it allowed high-rollers to play using other people’s credits, which could allow “guests to hide their identities and transactions” and play anonymously.

This year, the regulator fined Southern California’s Hawaiian Gardens Casino $2.8 million. USD fine for violation of anti-money laundering regulations. Hawaiian Gardens admitted it allowed players to gamble anonymously, even after gamblers became suspicious of the casino.

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The Sands case raised questions about how the two women ended up owing more than a million dollars after prosecutors filed charges in separate cases last year. In Nevada, defaulting on a gambling debt is a felony similar to keeping a bad check.

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Defense attorneys say the women, Chinese nationals living in the United States, made money by working as housekeepers and helping flashy Chinese gamblers visit casinos.

Navigating Forex Trading Regulations: Las Vegas Law Attorney's Expertise

The women could not be reached for comment. Their lawyers did not say how they got involved in the case or who paid their fees. Lawyers also refused to allow the women to be interviewed or provide documents confirming their profession and origin, but said they were still in the United States.

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Attorneys have filed motions seeking to overturn the casino. One statement said “Venice/Palazzo’s conduct may have violated federal criminal anti-money laundering laws.”

Setness and Rosenberg are former federal prosecutors, and this is not Rosenberg’s first run-in with Sands. As a former assistant US attorney, Rosenberg helped lead Ye Gon’s money laundering case against the company in 2013.

Casino marketing staff may be incentivized to break the rules, Rosenberg said in an interview, because they are paid in part based on how much customers play. “They need to be encouraged to care,” he said.

In order to prepare for the trial, the lawyers sent casino surveillance footage of the women in the betting rooms, along with their names and credit files.

Scott R Hokanson

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