“I understand that what they are seeking is approx $700k.  If correct, that will require a lot of explaining given what our other firms are charging and given the FCPA,” the Foreign Corrupt Practices Act.”
~General Counsel wrote to the company’s Macau executives in an email in late 2009.

Maybe you’ve heard a lot about Billionaire Sheldon Adelson lately … this is the guy who has said he’ll give as much as $100 million or even more to help elect Mitt Romney for President after having spent $10 million to push Newt Gingrich for President.  We know that 2/3 of all the money that Sheldon Adelson’s Sands Casino empire makes comes from their Macau casino (source).  And that money finds it’s way into Sheldon Adelson’s bank accounts … which then find their way into the bank accounts of Karl Rove and Mitt Romney political operations.

So – apparently the Department of Justice is investigating Billionaire Sheldon Adelson for violating the Foreign Corrupt Practices Act.  Emails have surfaced showing Sheldon Adelson personally directed funds of $700,000 directly to one Chinese official which they detailed as “expenses” despite two general counsel members telling him that it would be in violation of federal law.  Those two lawyers were fired and the $700k found it’s way to the Chinese official.  Coincidentally – Billionaire Sheldon Adelson received approval for his Macau casino off the coast of China.

Read the exclusive article from ProPublica & Frontline HERE:

Now, some of the methods Adelson used in Macau to save his company and help build a personal fortune estimated at $25 billion have come under expanding scrutiny by federal and Nevada investigators, according to people familiar with both inquiries.

Internal email and company documents, disclosed here for the first time, show that Adelson instructed a top executive to pay about $700,000 in legal fees to Leonel Alves, a Macau legislator whose firm was serving as an outside counsel to Las Vegas Sands.

The company’s general counsel and an outside law firm warned that the arrangement could violate the Foreign Corrupt Practices Act. It is unknown whether Adelson was aware of these warnings. The Foreign Corrupt Practices Act bars American companies from paying foreign officials to “affect or influence any act or decision” for business gain.

Federal investigators are looking at whether the payments violate the statute because of Alves’ government and political roles in Macau, people familiar with the inquiry said. Investigators were also said to be separately examining whether the company made any other payments to officials. An email by Alves to a senior company official, disclosed by the Wall Street Journal, quotes him as saying “someone high ranking in Beijing” had offered to resolve two vexing issues — a lawsuit by a Taiwanese businessman and Las Vegas Sands’ request for permission to sell luxury apartments in Macau. Another email from Alves said the problems could be solved for a payment of $300 million. There is no evidence the offer was accepted. Both issues remain unresolved.

We’ve written about Sheldon Adelson HERE:

PBS Newshour explains what has been found and how the investigation is working…

The Department of Justice explains the Foreign Corrupt Practices Act HERE:

The Foreign Corrupt Practices Act of 1977 … (“FCPA”), was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. Specifically, the anti-bribery provisions of the FCPA prohibit the willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.

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