After Singapore police began a probe of third-party transfers at Marina Bay Sands, parent company Las Vegas Sands (LVS) has hired a law firm to investigate the $1 billion in question.

Money Laundering?

The police probe prompted LVS to hire the law firm of Davinder Singh Chambers LLC to lead the investigation into the transfers. The firm specializes in dispute resolution and international arbitration, and has been hired to investigate questionable third-party transfers by Marina Bay Sands (MBS) employees.

Concerns over money laundering prompted the probe, which follows a similar investigation last year by the U.S. Dept. of Justice. A casino patron in that case sued over $6.7 million of his money which was transferred to other gamblers behind his back. The lawsuit was settled out of court in June.

Third-party transfers are legal when conducted properly. High roller junket tours specializing in trips from China to offshore gaming destinations use these transfers to get around China’s strict capital controls. But when handled improperly, the question of money laundering pops up.

Scrutiny over how MBS handles the third-party transfers led to last year’s suit and prompted the current investigation. Wealthy gamblers in Asia use the transfers to pool winnings and losses at different casinos, and junket operators trade Chinese cash for international gambling credit.

Due Diligence

In order for the third-party transfers to be legal, the casino patron must sign documents authorizing each transfer. However, in recent investigations into MBS, authorities found many instances of transfers which were either unsigned or merely photocopies of original documents. These copies were used in multiple transactions.

After an independent review, thousands of photocopied letters were used to facilitate transfers without original signatures. The Casino Regulatory Authority said it has completed investigations into the way MBS carried out unauthorized transfers from patrons’ accounts. They concluded that no money laundering allegations were levied on last year’s probes, they said there were weaknesses in MBS’ casino control measures.

MBS reported that they have strengthened the control process for third-party transfers, ensuring that gamblers authorize each fund transfer. In addition, casino staff receives training on how to spot and report suspicious activity regarding unlicensed junkets or money laundering.


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A Massachusetts native, blogger Angeline Everett grew up in the Allston neighborhood of Boston and earned a degree in casino management from the University of Massachusetts-Amherst. After graduating, Angeline moved to Atlantic City where she joined the young team at the Borgata Casino as a compliance representative, while blogging on the side. After a few years in the back office, Angeline moved to the floor to work first at a casual poker dealer and later casual poker floor supervisor. Fascinated with games of chance since she was a child, Angeline currently divides her time between blogging and work on her first book.