Status Report of Dr. Peter German's Recommendations
BCLC has addressed all recommendations for which it is responsible for from Dr. Peter German’s 2018 independent review of anti-money laundering policies and practices in Lower Mainland casinos.
Rec. # |
Description |
Status |
|---|---|---|
3 |
That BCLC, in conjunction with the Regulator and Service Providers, review the present Source of Funds Declaration on at least an annual basis to determine if refinements are required. |
Addressed |
4 |
That BCLC re-enforce the importance of Service Providers not accepting cash or other reportable instruments if they are not satisfied with a source of funds declaration. |
Addressed |
7 |
That BCLC provide Corporate Suspicious Transaction Reports (STRs) if its files contain relevant information not contained within an STR from a Service Provider. |
Addressed* |
10 |
That the Regulator / Designated Policing Unit be provided with access to iTRAK in its offices. |
Addressed |
11a |
That Unusual Financial Transaction (UFT) reports be eliminated. |
Addressed* |
16 |
That BCLC not engage in further undercover operations, except in conjunction with the Regulator and/or the police. |
Addressed |
17 |
That no further expense be incurred by BCLC with respect to the SAS AML software system. |
Addressed |
18 |
That BCLC ensure VIP hosts do not handle cash or chips. |
Addressed |
21 |
That cash limits not be imposed on buy-ins. |
Addressed |
22 |
That PGF accounts be eliminated once responsibility for cash alternatives has transitioned to the service providers.
Note: This is dependent on completion of Recommendation 20: That cash alternatives become the responsibility of the Service Providers, subject to their compliance with overarching standards. |
Addressed |
23 |
That BCLC implement a chip tracking system for Service Providers. |
Addressed |
R0.1 Interim |
Service Providers must complete a Source of Funds Declaration for cash deposits or monetary instruments of $10,000 or more. This includes the requirement for customers to provide evidence of the source of their buy-in funds. |
Addressed |
*BCLC remains the casino industry’s reporting entity to FINTRAC, and continues to evolve and improve its anti-money laundering program, which is subject to frequent independent reviews to ensure its ongoing effectiveness. As such, the following recommendations are no longer required:
Recommendation 7: That BCLC provide corporate Suspicious Transaction Reports (STRs) if its files contain relevant information not contained within an STR from a Service Provider. This is dependent on the completion of R5: That Service Providers be responsible for completing all necessary reports to FinTRAC, including Suspicious Transaction Reports (STRs).
Recommendation 11a: That Unusual Financial Transaction (UFT) reports be eliminated. This is also dependent on the completion of R5.
Current UFT and STR reporting obligations will continue.