Recent government interest and media attention surrounding the gaming industry should have gaming companies and their business partnersboth foreign and domesticon alert. The gaming industry is highly regulated throughout the world, and gaming companies operating abroad almost invariably have contact with foreign governments. Foreign Corrupt Practices Act (FCPA) regulators in the United States have taken note. According to company filings, Las Vegas Sands is currently under investigation by the U.S. Department of Justice and the Securities Exchange Commission for alleged violations of the FCPA relating to its operations in Macau, China.
If history is any indication, this investigation may be just the tip of the iceberg. It is no secret that FCPA investigation and enforcement has become a major focus of government regulators in recent years, and has been one of the fastest-growing areas of federal law enforcement. The Las Vegas Sands FCPA investigation likely signals that FCPA regulators may see the gaming industryan industry already subject to a high level of government scrutinyas an area which, by its very nature, is particularly susceptible to running afoul of the FCPA. In short, gaming businesses can be more certain than ever that their actions will be highly scrutinized by the U.S. government.
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