Inside Asian Gaming

December 2012 | INSIDE ASIAN GAMING 7 Sheldon Adelson, the company’s famously combative chairman, who has said he fears “vilification” as an outspoken foe of the Obama administration, spent 2012 writing enormous checks to Republican candidates, political action committees and dark money non-profits to try to keep Mr Obama from returning to theWhite House. Had he succeeded it’s likely his FCPA worries would be behind him. As it stands, $150 million or so in direct and indirect campaign contributions later, his company is also the target of a federal probe into alleged money-laundering at its Las Vegas casinos. Mr Adelson was planning to travel to Washington this month, according to a Huffington Post report, to meet with Republican lawmakers. The agenda was to include the Foreign Corrupt Practices Act, the Post said, citing party insiders. “It looks like Sheldon is shooting himself in the foot when it comes to the FCPA,”says a source with ties to the regulatory authorities in Macau. For what it’s worth, Mr Wynn is also a major Republicandonor. Similarlyoutspoken in his dislike for the Obama presidency, he acknowledged “urging” his 12,000 Las Vegas employees to vote for Mitt Romney. Love Gone Sour In January 2011, Wynn’s independent directors led by former Nevada Gov. Bob Miller, who chairs the board’s Compliance Committee, undertook the first of two risk assessments of the Philippines. Their conclusion was that corruption is “deeply ingrained” in the gaming industry there and that newly elected President Benigno Aquino wasn’t likely to do much about it. The committee also claimed to have evidence leading to “reasonable suspicion that persons acting on Okada’s behalf had engaged in improprieties,” possibly a reference to the allegations currently swirling around Boysee Soriano. According to the company’s 2012 lawsuit, these findings were presented at a board meeting the following month with Mr Okadapresent.SteveWynnannouncedatthe meeting that he’d been invited by Mr Okada to meet with Mr Aquino. The independent directors responded that “involvement in the Philippines was inadvisable” and recommended against it. The meeting with Mr Aquino was canceled. Mr Okada was “embarrassed and angry”. The committee’s second investigation, commissioned that August, went further, declaring that it had “identified anomalies and improprieties in Universal/Okada’s dealings in the Philippines”. The findings included concerns that Mr Okada was “engaging in acts that would render him unsuitable under Nevada gaming regulations, and breaching the fiduciary trust duties he owed Wynn Resorts”. Sometime around the end of October, Washington, D.C.-based Freeh, Sporkin & Sullivan was brought in “to examine Mr Okada’s efforts in connection with the creation of a gaming establishment in the Republic of the Philippines”. Specifically, the board wanted something definitive on whether Mr Okada “may have breached his fiduciary duties to Wynn Resorts; engaged in conduct that potentially could jeopardize the gaming licenses of Wynn Resorts; and/or violated the Wynn Resorts compliance policy”. It’s difficult to imagine that Mr Okada …but not quite kingmaker In January 2011, Wynn’s independent directors led by former Nevada Gov. Bob Miller undertook the first of two risk assessments of the Philippines. Their conclusion was that corruption is “deeply ingrained” in the gaming industry there and that newly elected President Benigno Aquino [pictured here] wasn’t likely to do much about it.

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