“Buchalter Attorney and former federal prosecutor Daniel Silva, who led the investigation while at the US Attorney’s Office, told Gaming America:
The criminal penalty paid by Wynn is the largest criminal penalty in the history of the Department of Justice for a casino. The criminal conduct involved third-party businesses, agents and related entities in the United States, Latin America and Asia. These third parties acted as separate, unlicensed financial institutions – known as ‘money transmitting businesses.’ Through the use of these money-transmitting businesses, gamblers at Wynn (and Wynn itself) were able to evade foreign and US laws governing monetary transfer and reporting.
These transfers were extremely sophisticated, allowing for international underground banking transfers that concealed the true ownership, nature and source of the funds, which is contrary to the transparency intended by America’s anti-money laundering legal regime – known as the ‘Bank Secrecy Act.'”
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