According to a US Attorney’s Office statement, WLV forfeited $130,131,645 to “settle criminal allegations that it conspired with unlicensed money transmitting businesses worldwide to transfer funds for the financial benefit of the casino”.

It is also believed to be the largest forfeiture by a casino based on admissions of criminal wrongdoing.

US Attorney Tara McGrath commented: “Casinos, like all businesses, will be held to account when they allow customers to evade US laws for the sake of profit. 

“Federal oversight seeks to prevent illegal funds from tainting legitimate businesses, ensuring that casinos offer a clean, thriving, and safe entertainment option.”

Through the non-prosecution agreement, which allows a company or individual to avoid criminal prosecution in exchange for meeting certain criteria, WLV “admitted that it illegally used unregistered money transmitting businesses to circumvent the conventional financial system”.

Wynn Resorts noted within an SEC filing that the agreement with DOJ and Attorney’s Office resolves “previously-disclosed investigation into various transactions at Wynn Las Vegas relating to certain patrons who reside or operate in foreign jurisdictions which were facilitated by former employees, agents and other third parties that were unlicensed money transmitting businesses, in violation of 18 U.S.C. § 1960”.

In addition to the $130m forfeited, Wynn Resorts agreed to “continue to make certain enhancements to its compliance program”. Subject to WLVs’ fulfilment of its agreement obligations, the DOJ will not bring “any criminal charges against Wynn Las Vegas concerning the subject matter of its investigation, subject to standard reservations of rights and certain reserved claims”.

According to the US Attorney’s Office, WLV “regularly contracted with third-party independent agents acting as unlicensed money transmitting businesses to recruit foreign gamblers” to the casino.

To make sure gamblers repaid their debts to WLV or had funds available to gamble, the independent agents “transferred the gamblers’ funds through companies, bank accounts, and other third-party nominees in Latin America and elsewhere, and ultimately into a WLV-controlled bank account in the Southern District of California”. These funds would then be transferred into a WLV cage account. 

“WLV employees, with the knowledge of their supervisors, and working with the independent agents, eventually credited the WLV account of each individual patron,” noted the US Attorney’s Office.

“The convoluted transactions enabled foreign gamblers at WLV to evade foreign and US laws governing monetary transfer and reporting.”

In reaching the agreement resolution, Wynn Resorts’ SEC filing noted that the DOJ accounted for “the historical nature of the transactions at issue; Wynn Las Vegas’s cooperation with the DOJ’s multi-year investigation; that Wynn Las Vegas no longer employs or is affiliated with any of the individuals implicated in the transactions at issue; and Wynn Las Vegas’s extensive remedial measures, many of which were undertaken prior to the parties entering into the NPA”.

In addition, the SEC filing stated that “all prior US federal regulatory inquiries commenced in or about 2014 regarding compliance by Wynn Las Vegas with 18 U.S.C. § 1960 and the Bank Secrecy Act” have been resolved through the agreement.

Christopher Davis, acting special agent in charge for HSI San Diego, said: “Of the many unique authorities HSI is able to enforce, understanding and investigating complex financial crimes that lead to holding criminals accountable for their actions, is one that HSI does best. 

“The success of this investigation is in part due to our partner agencies’ cooperation and dedication to seeing these long-term investigations through to bring justice to these companies and protect American financial institutions.”

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The report also outlines how the company’s ongoing recovery from the global pandemic ran parallel to achieving a range of progressive ESG and Diversity, Equity and Inclusion goals, with significant strides made in community outreach and crisis relief efforts, responsible business practices, and protecting human rights.

In the report, Matt Maddox, CEO of Wynn Resorts, remarked: “A truly great company, one founded on the belief that excellence is not just an aspiration but a necessity, and operating in today’s socially and environmentally-fraught world, is called to a higher standard: to take responsibility, not just for our decisions, but for the all future impacts of those decisions. Impacts we ourselves may not live to see, but will have caused, nonetheless. 

“Decision-making with careful consideration to the impacts 20 or 30 years from now isn’t just essential, it’s an existential imperative. That is what the future demands of us.”

The sustainability programme, known as Goldleaf, houses scientific solutions to the wide range of environment and climate challenges that are unique to each resort operated by the company. 

Under the direction of CEO, Matt Maddox, and Chief Sustainability Officer, Erik Hansen, the company has committed to reduce or offset all carbon dioxide produced by its operations no later than 2050; to stop and reverse year-over-year growth of operational carbon dioxide emissions by 2030; and to increase its supply of renewable energy produced or procured to at least 50 per cent of total consumption by 2030.

These commitments are aligned with the recommendations made by the Intergovernmental Panel on Climate Change for limiting global warming to below 1.5 degrees Celsius, as referenced in the 2015 Paris Climate Accord. 

In 2020, the company completed several major projects in renewable energy, waste diversion, and emissions reduction, many of which were years in the making. These include: installing 23 Megawatts of solar power capacity in the United States and reducing its annual energy consumption by 20 per cent in 2020 relative to 2015 through capital investments in critical energy-reducing technologies and operational efficiencies. 

Additional objectives will see the firm towards receiving 100 per cent of Encore Boston Harbor’s energy from renewable and green sources of power and diverting 100 per cent of its waste from landfill in 2020, whilst also reducing Wynn Las Vegas’ Carbon Dioxide emissions by over 80,000 metric tonnes from 2019 to 2020.

Additionally, the report showcases long-standing corporate values and core behaviors that govern fair, transparent, and ethical behavior. Under the pillars of Our People, Our Communities, and Our Planet, highlights in the key areas of COVID-19 pandemic relief, social impact, corporate governance, DEI, and human rights include: CEO Matt Maddox spearheading the creation of the hospitality industry’s first science-based Health & Safety Plan; Wynn Las Vegas collaboration with University Medical Center to open the UMC COVID-19 Vaccination Centre and its construction of the Lighthouse Lab COVID-19 testing facility. 

Globally, the company donated $23m in funds and in-kind donations to charities in 2020, which includes $4.75m in direct COVID-19 relief efforts and its workforce volunteered over 34,000 hours of time in 2020. 

Meanwhile, the Wynn Resorts Human Rights Policy broadened in 2020 to include specific expectations and core principles for diversity, inclusion, and non-discrimination; and lastly, extensive training and security procedures were enhanced in 2020 to combat human trafficking and commercial sexual exploitation.

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This says that if you’ve been fully vaccinated you can resume activities that you did prior to the pandemic; and that you can resume activities without wearing a mask or staying six feet apart, except where required by federal, state, local, tribal, or territorial laws, rules, and regulations, including local business and workplace guidance.

Furthermore, the guidance also says that if travel is undertaken in the US, individuals do not need to get tested before or after, or self-quarantine upon its culmination.

In updating its own guidance, the NGCB once again stressed pride at “the industry’s outstanding efforts to vaccinate its hospitality workforce.”

Nevada will be following the latest recommendations on masking from @CDCgov and @NVHealthRespon1 will be issuing more information later today.

I strongly urge all Nevadans who have not yet taken advantage of the #COVID19 vaccine to do so as soon as possible. https://t.co/xGG9aICL74

— Governor Sisolak (@GovSisolak) May 13, 2021

It adds that “this remarkable work, resulting in vaccination of a substantial percentage of the people who make up the hospitality workforce, will benefit the gaming industry, the local governments that rely upon the gaming economy, and, ultimately, it will benefit the state.”

Updates to Emergency Directive 045 state that: 

• The Board neither requires nor prohibits gaming licensees from confirming patron vaccination status. Licensees are encouraged to post signage with the latest CDC mask guidance for vaccinated and unvaccinated guests.  
• The Board’s agents will not attempt to confirm vaccination status of patrons. Consequently, unless circumstances change, it is not practical for the Board to attempt to enforce a mask mandate tethered to an individual’s vaccination status.  
• Licensees may have mask policies that are more restrictive than the CDC guidance. Staff should consult with their employers regarding workplace COVID-19 safety protocols. 

Wynn Las Vegas has already moved to clarify its own position, saying that beginning today “Wynn Las Vegas and Encore will communicate to guests that they are not required to wear a mask if they are fully vaccinated and are required to wear a mask if they are not”.

Furthermore, the company currently has a vaccination rate of 91 per cent among its employees in Las Vegas and as a result, was granted permission by the NGCB to amend its occupancy and physical distancing requirements.  

Effective May 10, the gaming areas at both properties were also permitted to run at 100 percent occupancy, and plexiglass dividers were removed from all table games and slot machines

Wynn becomes one of many to have been cleared for 100 per cent gaming floor capacity, with MGM Resorts International, Caesars Entertainment, and Boyd Gaming, making similar statements this week.

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The comprehensive facility verification helps ensure that guests and travel planners can visit properties with confidence that they have the appropriate health and safety procedures in place.

“We are thrilled to be one of the first resorts to receive this important verification from Sharecare and Forbes Travel Guide,” said Jeff Hamilton, president and general manager of Mohegan Sun. 

“This is another testament to our team’s hard work and ability to quickly adapt in the unpredictable environment we live in. We will continue to be an innovative force in the hospitality industry by remaining dedicated to providing a safe atmosphere for guests while delivering exceptional guest service.”

The verification comes with an easily identifiable ‘seal of approval’ – the Sharecare verified with Forbes Travel Guide badge – based on the property’s compliance with expert-validated best practices that minimise the risk and impact of COVID-19 and potential future public health events.

“We have worked tirelessly to develop rigorous health and safety practices to ensure that our guests feel safe when visiting,” stated Marilyn Spiegel, president of Wynn Las Vegas and Encore. 

“This verification is a testament to our efforts as we continue to offer our guests the latest health safety advancements and the very best five-star resort experience.”

Developed by Forbes Travel Guide and digital health industry leader Sharecare, the verification covers more than 360 standards across health and hygiene protocols, cleaning products and procedures, ventilation, physical distancing, the guest experience, and health safety communication with guests and employees. 

Properties are required to verify their health protocols on an ongoing basis to ensure continued compliance with the most up-to-date global health standards.

“The pandemic has made it clear that hotels and resorts must, first and foremost, assure guests of their safety,” said Filip Boyen, CEO of Forbes Travel Guide. 

He adds that by becoming verified, both properties have demonstrated a “commitment to creating a culture of accountability and following global best practices to heighten health security, certified by a third party.”

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Bringing an extensive gaming background to the position, it follows a strategic partnership made alongside Malta-based European mobile sportsbook and casino operator BetBull.

Under the terms of the agreement, within which it was stated that both party’s intend to “capitalise on the developing US opportunity” across multiple US jurisdictions, Wynn Resorts is to combine its “nationally recognised brand” with BetBull’s “digital sports betting operations capabilities and technology”.

Castaneda began his 23-year journey at Stardust Resort and Casino and Boyd Gaming in 1995, undertaking a number of varying sportsbook roles as he rose through the ranks to management.

Upon leaving Stardust, Castaneda joined Wynn Las Vegas as a shift manager, becoming a critical member of the opening team.

Previously working under the leadership of Johnny Avello, former director of race and sportsbook operations at Wynn Las Vegas, Castaneda has been heavily lauded for the “integral role” played in the subsequent success.

“It has been a privilege to see Doug grow exponentially at the Wynn, and we couldn’t be more excited to have him bring his passion and expertise to this role,” said Wynn Las Vegas president Maurice Wooden. “We are confident that he will continue to provide our guests with an unrivalled Las Vegas experience as well as unparalleled service.”  

This follows news that Wynn Resorts’ Encore Boston Harbor, currently under construction in Everett, Massachusetts, is to pledge $10m to support social programs and civic institutions within the state, as detailed in the Las Vegas Review-Journal.

“Giving back to the communities where our employees and guests live and work has always been a part of who we are as a company,” stated Wynn Resorts CEO Matt Maddox. “It’s not in our corporate DNA to just write a check for a donation or buy a table at a charity event. We want to make an impactful difference in the lives of people and effect real and positive changes in our communities. We believe committing $10m and teaming with the Connors Family Office will go a long way toward realising our goal.”

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Becoming the largest Green Power partner within the hotel industry and the only casino resort from Nevada on the list, Wynn joins a collection of organisation that the EPA states “are voluntarily leading the innovation, production and use of green energy in America”.

Wynn’s latest green initiatives follows the opening of its 160-acre solar complex, that is solely dedicated to generating renewable energy to power its Las Vegas entity.

Combined with 103,000 square feet of on-site rooftop solar panels, Wynn Las Vegas is creating and using more than 45 million kilowatt-hours of green power annually, which is enough to meet 25 per cent of the resort’s electric load.

According to the US EPA this is the equivalent to the annual electricity use of more than 4,000 average American homes, and subsequently qualifies Wynn Las Vegas to join “an elite group of of Fortune 500 companies that are current Green Power partners,” such as Microsoft, Intel, Bank of America, Apple, Johnson & Johnson and Starbucks.

Erik Hansen, chief sustainability officer for Wynn Resorts, commented: “It is an honour to be recognised by the US EPA for our commitment to protecting our planet’s resources.

“We are proud to be the national leader in green energy use in the hotel industry, proving that integrating large-scale energy efficient measures can be done in a way that only enhances the guest experience.”

Earlier this month Wynn Resorts announced its intention to join the US sports betting scene, with the organisation’s late entry made alongside Malta-based European mobile sportsbook and casino operator BetBull.

The deal saw Wynn take a minority equity investment stake of 22.5 per cent in the firm, “on a fully-diluted basis upon closing of the investment, which will occur in due course subject to customary closing conditions”.

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Set to pursue US facing sports betting opportunities amidst the emerging gold-rush of the market, the fresh agreement alongside the UK licensed entity aims to position “both parties to capitalise on the developing US opportunity”.

In a media statement confirming the link-up, it was further highlighted that as both firm’s get set to pursue opportunities in further jurisdictions across the country, Wynn Resorts is to combine its “nationally recognised brand” with BetBull’s “digital sports betting operations capabilities and technology”.

Furthermore, Wynn, whose current operations are located entirely within Nevada, namely its Encore Las Vegas and Wynn Las Vegas, which both operate sportsbooks, are also to take an ownership stake within the firm: “In conjunction with the formation of the strategic partnership, Wynn Resorts will make a minority equity investment in BetBull.

“Wynn Resorts will own 22.5% of BetBull on a fully-diluted basis upon closing of the investment, which will occur in due course subject to customary closing conditions. Moelis & Company LLC acted as financial advisor to Wynn Resorts,” it was confirmed.

Wynn is currently developing its $2.5bn project located in Everett, Massachusetts, which it has previously been detailed has ditched the Wynn moniker, and will instead bear the title of Encore Boston Harbor.

It was hoped that by ditching the Wynn name, as well as Steve Wynn’s departure from the role of CEO, adequate evidence would be provided for it to remain as the licensee for the ongoing project, which led to the Massachusetts Gaming Commission giving the organisation the green-light to continue operations earlier this year.

Beats breakdown: This move by Wynn sparks a late entry to the sports wagering scene, which has already captured significant manoeuvres from a number of its rivals, as the likes of MGM, Boyd Gaming and Eldorado Resorts to name but a few, position themselves to most effectively strike across the US. It’s also a bold statement to lead the partnership with a nationally tarnished brand such as Wynn, in the hope that it holds significant leverage and appeal in multiple new regions in the wake of damaging headlines throughout the year, but time will tell.

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