Sheldon Adelson [3], Las Vegas casino magnate and GOP mega-donor, is being investigated by the U.S. Justice Department [4] under suspicions he violated the Foreign Corrupt Practices Act (FCPA) [5] while dealing with the Chinese government and his Macau casino ventures. The FCPA, introduced in 1977 [6] by U.S. Senator William Proxmire (D-WI), prohibits American companies from bribing foreign government officials.

Emails leaked by ex-company employees prompted the investigation and the breaking story by ProPublica [7] and PBS's Frontline. Adelson allegedly instructed a top executive to make a $700,000 payment [8] to Leonel Alves, a Macau legislator, member of the advisory board to the chief executive of Macau, and lawyer whose law firm was helping Adelson's Las Vegas Sands casino set up shop in Macau. Adelson and Las Vegas Sands had sought Alves' help in resolving two issues -- a lawsuit by a Taiwanese businessman and permission to sell luxury apartments in Macau -- and he apparently came through. Approximately two-thirds [9] of Las Vegas Sands' income now comes from Macau.

Emails [10] from 2009 obtained by ProPublica showed that Las Vegas Sands executives viewed Alves as "uniquely situated both as counsel and legislator to 'help' us in Macau," but the company's then-general counsel warned that Alves' legal fees were triple his normal rates, which could raise concerns under the FCPA.

"I understand that what they are seeking is approx $700k," the general counsel wrote [11] to the company's Macau executives in late 2009. "If correct, that will require a lot of explaining given what our other firms are charging and given the FCPA."

The FCPA bars American companies from paying foreign officials to "affect or influence any act or decision" for business gain.

Despite warnings from Las Vegas Sands' general counsel that the payment could run afoul of the FCPA, Adelson apparently instructed executives to pay the full amount, according to an email quoting his instructions obtained by ProPublica. [10]

Other documents also suggest improper dealings. One email from Alves [12] indicates some of the issues could be resolved with Chinese officials for $300 million (although there is no evidence this was paid). An invoice from Alves [13] showed that he charged $18,000 to accompany Adelson to Beijing. Another [13] shows he billed $25,000 in "expenses" with no further explanation.

Adelson's investments in Macau have been the source of much of his wealth (his personal fortune is estimated at $25 billion).

And this election cycle, he has been using that wealth to back Republican candidates.

Adelson and his family gave $25 million to prop-up Newt Gingrich's failed presidential run. He has reportedly given $10 million to the SuperPAC supporting Mitt Romney (and his willingness to continue supporting Romney is said to be "limitless" [14]). Adelson and his wife have also given $5 million to Eric Cantor's SuperPAC, the "YG Action Fund." An individual search on the Federal Election Commission website [15] shows Adelson contributed over $14 million of "soft money" [16] to PACs.