Bloomberg News published a story this week stating that FinCen is investigating Mark Brown, described by various news sources as a “Trump protege”, for suspicious financial activity at the Saipan-based casino, “Best Sunshine Live“. The same casino pays cash to a number of political luminaries, including 3 former US governors, as well as former heads of the CIA and FBI.

For instance, Pennsylvania Gov. Ed Rendell is paid $5,000 a month by a land-based casino on the island of Saipan. The payments are made to Rendell for his role on Best Sunshine Live’s “advisory committee for business strategies and government relations“.

Bloomberg reporters Daniela Wei and Matthew Campbell wrote that the U.S. Treasury’s Financial Crimes Enforcement Network (FinCen) is investigating Best Sunshine Live Casino. The most suspicious part of the operation is its reported revenues, which are astronomical compared to its seeming location and profile.

Best Sunshine Live Casino

Best Sunshine Live operates on the tiny island of Saipan in the Marianas Islands, which are located in the Western Pacific Ocean. The casino is said to be located between a cellphone repair shop and a laundrymat. It is by no means one of the 21st Century style “integrated resorts” found in Las Vegas, Macau, and Singapore.

Despite its location, the casino reported an immense $3.9 billion in turnover in September 2016. according to the own of the casino, Imperial Pacific International Holdings. Imperial Pacific is listed on the Hong Kong Stock Exchange (HKSE), so it is required to post revenue figures.

Comparison to the Las Vegas Strip

Readers should keep in mind that the turnover is not the same as revenues, and certainly not the same as profits. The turnover is how much money was wagered at the casino. If one assumes a cumulative house edge of 5% on all the games in the casino, then the revenues would be $195,000,000 in the month of September.

Over the course of a year, the revenues for the Best Sunshine Live casino would be something in the range of $2.34 billion. The entire Las Vegas Strip, consisting of the world’s most famous casinos, generated a total of $6.3 billion in gaming revenues 2015. While the cumulative house edge at Best Sunshine Live might be more or less than 5%, few would argue that the casino generates anything in the range of 35% of the revenues of the Las Vegas Strip in a year’s time.

In short, the posted turnover for Best Sunshine Live is absurd. Bloomberg’s reporters speculate that the casino’s posted turnover might indicate corruption in the form of money laundering. Casinos are a perfect location for money laundering, because of the huge amount of cash which changes hands in a day’s time. That is one reason American mobsters traditionally operated in the casino industry, besides the obvious profit motive.

Money Laundering in the Casino Industry

For decades, RICO laws in the continental United States have (more or less) assured that Las Vegas and Atlantic City casinos do not allow money laundering. Occasionally, federal regulators fine a casino for money laundering, like the $47 million fine assessed to the Las Vegas Sands Corporation in the past year for possible money laundering back in 2005-2006.

A more remote location like Saipan would be a more natural place for money laundering to take place. The problem for Imperial Pacific, Mark Brown, and Ed Rendell is Saipan is a U.S. overseas territory. FinCen’s probe could net money laundering charges under US law.

Philly.Com’s Reporting on Ed Rendell

Philly.com, the online version of the Philadelphia Inquirer, reported that Ed Rendell (or “Fast Eddy” as they call him) answered questions on allegations of wrongdoing.

Ed Rendell said he has been accepting $5000 payments for the past “6 or 7 months” for his role on the advisory council. The former mayor of Philadelphia said he had “did a little due diligence” before agreeing to the arrangement. He added that Imperial Pacific “seemed fine”.

Ed Rendell and Mark Brown

That due diligence appears to have been a conversation with Mark Brown. Rendell said, “I said to Mark, ‘Is this legit?’ He said, ‘Yes.’ I said, ‘Is it a real casino?’ He said, ‘Yes, it is.'”

Then the Democratic politician said he trusted Mark Brown. He added, “I relied on my conversation with Mark Brown that it was real. If it proves to be a shell, I’m resigning immediately.

Paterson, Freeh, and Woolsey

Rendell said that former New York Gov. David Paterson, who is a member of the advisory council, pitched him on the deal. Former FBI Director Louis Freeh and former CIA Director James Woolsey also sit on the advisory council.

When asked what he had done in his role, Rendell said only that he had recruited another member. He said, “The only thing I did was, I persuaded Haley to sign up,” referring to former Mississippi Gov. Haley Barbour.

About Mark Brown

The 55-year old Mark Brown has been in the casino industry for decades. He got his start at Atlantic City’s Resorts International in the late 1970s. Later, he was the CEO of Trump Hotels and Casinos Inc., serving in that capacity until 2005. Brown exercised a clause that allowed him a buyout if Donald Trump ever owned less than 35% of (what was then known as) Trump Entertainment Resorts.

Since then, Mark Brown has worked the Las Vegas Sands Corporation, heading individual casinos like The Venetian Macau, Sands Macau, and The Four Seasons Macau. He helped make the Venetian Macau the most successful casino in the biggest gaming destination in the world. At its height, Macau generated 7 times the gaming revenue of Las Vegas in a year.

Mark Brown left LVS to join Wynn Resorts’s multi-billion dollar Cotai Strip Macau project, but left that organization again in 2014 to lead Imperial Pacific Ltd’s $7.1 Billion casino resort project in Saipan. With such a huge price tag, Best Sunshine Live needs to make a massive amount of cash. The question is: can a casino resort in the middle of the Pacific Ocean make more than casinos in Macau or Las Vegas?

FinCen’s plans to investigate, so readers should learn the truth in time.

About the Author
April Bergman avatar
April Bergman

April Bergman was a longtime news blogger for BOC. She wrote gaming news posts from January 2013 until September 2018. April also wrote slot reviews, strategy articles, and online casino reviews for the site.

April Bergman began in the online gaming industry in August 2010. From 2010 to 2013, she managed evergreen content for several top online casino. Her duties included developing and maintaining multiple websites in the gaming space. When not writing about online gambling, April loves horse racing, travel, photography, and gardening. She's began in the business as a devoted poker players and spent several years as a card game editor on the now-defunct DMOZ. These days, she lives with her husband and two children in the Toronto metropolitan area.

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April Bergman was a longtime news blogger for BOC. She wrote gaming news posts from January 2013 until September 2018. April also wrote slot reviews, strategy articles, and online casino reviews for the site.

April Bergman began in the online gaming industry in August 2010. From 2010 to 2013, she managed evergreen content for several top online casino. Her duties included developing and maintaining multiple websites in the gaming space. When not writing about online gambling, April loves horse racing, travel, photography, and gardening. She's began in the business as a devoted poker players and spent several years as a card game editor on the now-defunct DMOZ. These days, she lives with her husband and two children in the Toronto metropolitan area.

READ MORE
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