On January 19, 2017, Las Vegas Sands Corp., a Nevada gaming and resort company, entered a non-prosecution agreement and agreed to pay $6.96 million to resolve alleged FCPA violations in connection with transactions in China and Macao.  According to admissions in the agreement, Sands failed to implement effective internal accounting controls to ensure the legitimacy of payments to a consultant promoting the Sands brand in China and Macao.  Sands also failed to prevent the false recording of those payments in its books and records and continued to make payments to the consultant despite warnings from its finance department and an outside auditor that the consultant had failed to account for portions of the funds paid to him.  Sands received a 25% downward departure from the bottom of the U.S. Sentencing Guidelines fine range on the basis of cooperation with DOJ’s investigation and remedial measures to revamp and expand its compliance and audit functions. DOJ Press Release