THE M3: GGR SHARE AS OF OCT 21; SANDS CHINA MEMOS

The Macau Metro Monitor, October 21, 2011

MACAU CASINOS HEADING TOWARDS NEW RECORD: REPORT Macau Business

According to Jornal Tribuna de Macau, as of Oct 19, Macau GGR reached MOP17BN (HK16.6BN, US2.13BN).  October is on track to reach a new monthly record.  In terms of market share, SJM 26%, Galaxy 22%, LVS 'close to 15%', MPEL 14.5%, WYNN 13%, and MGM 9.5%.

SANDS INVESTIGATION COMES INTO FOCUS WSJ, Macau Business

An internal memo from LVS General Counsel, Gayle Hyman, shows that LVS is seeking to secure a list of government officials who have gambled its Macau casinos.  Macau law prohibits local government officials from gambling.  LVS disclosed in March that the SEC and the U.S. Justice Department were investigating whether the company violated the Foreign Corrupt Practices Act (FCPA).

Hyman's memo instructs employees at Sands to retain documents regarding "transmission of anything of value" to current and former Macau government officials and their family members.  The memo also names several Sands employees and contractors about whom documents must be preserved.  Among those people is a prominent Macau lawyer--Leonel Alves, a Macau legislator, a member of the Macau government's top advisory body and a member of China's top political advisory body, the Chinese People's Political Consultative Conference--who is a focus of a dispute between Sands China and its former CEO Steve Jacobs.  An outside counsel for LVS called the memo "extremely standard operating procedure" and said it is no indication of whether the documents that were requested actually exist. 

In another memo, LVS has hired Ira Raphaelson, a special counsel in the Justice Department during the administration of President George H.W. Bush, to the new position of global general counsel.  Hyman will take the new position of senior vice president of corporate affairs and report to Mr. Raphaelson, according to the memo, which was sent by Chairman Sheldon Adelson.

LVS has hired law firm O'Melveny & Myers LLP to conduct an independent investigation of the company in connection with the government probe.  In July, a 30-member team from the firm went to Macau to collect documents.  The O'Melveny team looked at the activities of at least two Sands China staff with connections to the Macau government that aren't named in Ms. Hyman's memo.  One of those people cited by O'Melveny is the company's vice president of community relations Melina Leong.  Ms. Leong is the sister of Lionel Leong, a member of Macau's executive council, who is considered a potential future CEO of Macau.