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BCLC’s Anti-Money Laundering Actions

BCLC has continued to improve its anti-money laundering (AML) controls as part of our ongoing effort to safeguard B.C. casinos from illegal activity. Below is a chronology of key actions from 2012 to current:

Encouraged Use of Non-Cash Transactions

With the exception of one pilot, BCLC was permitted to take only cash from customers prior to June 2012.

June 2012: BCLC implemented policy changes to encourage the use of non-cash transactions to reduce the flow of large amounts of cash in casinos. This included allowing B.C. casinos to offer Patron Gaming Fund (PGF) accounts.

A PGF account is for gaming-use specifically and exists to facilitate gaming play – not to provide financial services typically offered through personal bank accounts. PGFs allow players to transfer money between their PGF account and their approved bank account (as defined by the Office of the Superintendent of Financial Institutions), eliminating the need to bring cash into a casino. Transactions are traceable.

October 2012: BCLC identified and barred an individual suspected of having links to criminal activity and providing off-site cash deliveries.

New Dedicated Anti-Money Laundering Unit

September 2013: BCLC created a dedicated Anti-Money Laundering (AML) Unit, which ensures BCLC’s compliance with AML regulations and guidelines, and conducts intelligence gathering and analysis. At this time, BCLC required employees working in the AML Unit to acquire Association of Certified Anti-Money Laundering Specialist (ACAMS) professional certification, believed to be the first requirement of its kind in the industry.

Ongoing reporting of Suspicious Transactions

February 2014: BCLC implemented a program to monitor players and transactions on an ongoing basis. Where concerns arise in relation to a player or transactions, BCLC reports those players and transactions to police, the gambling regulator and FINTRAC.

April 2014: BCLC met with the Combined Forces Special Enforcement Unit of the RCMP and requested police assistance regarding increased large-cash transactions and suspected illegal activities.

June 2014: BCLC established an Information Sharing Agreement with police to support BCLC in identifying and proactively banning individuals from B.C. casinos who are suspected of criminal activity, believed to be a public safety risk or members of organized crime groups.

July 2014: BCLC supplied to police a list of Top 10 suspected cash facilitators associated with another individual linked to organized crime.

November 2014: BCLC presented a proposal to the Combined Forces Special Enforcement Unit of the RCMP to investigate individuals suspected to be engaging in criminal activity in proximity to casinos.

Requirements for Players to Disclose Source of Funds

February 2015BCLC requested that the RCMP’s Federal Serious and Organized Crime unit initiate an investigation based on information that BCLC had collected related to cash drops at casinos by an individual believed to be associated to organized crime. Shortly thereafter, the RCMP launched its “E-Pirate” multinational money laundering investigation.

April 2015: BCLC began placing certain players on sourced-cash conditions, meaning that they could not play with cash unless they could disclose the source of their buy-in funds. In summer 2015, BCLC further revised and extended its source of funds program (which was expanded on in January 2018), intended to protect casinos from criminal proceeds, and continued to place players on the cash conditions. Since 2015, we have placed these conditions on more than 520 players.

New Protocol Introduced to Help Safeguard Casinos

January 2016: BCLC replaced the series of $5,000 denomination casino chips at River Rock, rendering the prior chips worthless, thereby reducing the potential for individuals to use them for illicit purposes.

October 2016: BCLC established a protocol to ensure that players are unable to attend a casino and attempt to buy-in with cash that another B.C. casino has already declined, unless authorized by BCLC’s AML Unit following its review of the circumstances.

Implementation of Reasonable Measures Process

June 2017: BCLC implemented a Reasonable Measures process that requires casino operators to complete enhanced due diligence in determining and documenting the ownership of funds for all cash buy-ins, disbursements and foreign exchange transactions of $10,000 or more within a static 24-hour period.

Enhanced Source of Funds Requirements

January 2018: BCLC implemented Dr. Peter German’s first interim recommendation, by expanding Source of Funds procedures in B.C. casinos. All casino operators must complete a Source of Funds Declaration for all cash and bank draft/certified cheque forms of buy-ins of $10,000 or more, which includes recording detailed information about where the player sourced funds before the player is allowed to buy-in. In addition to the interim recommendation, BCLC implemented a requirement for all players to provide an original receipt from a financial institution, as proof of source of funds.

March 2018: BCLC implemented a policy that prohibited casinos from taking any form of payment from a Money Service Business.

June 2018: The Ministry of the Attorney General released an independent report of anti-money laundering policies and practices in B.C. casinos. The report identified 48 recommendations to improve anti-money laundering controls.

German Recommendations Progress

January 2019: BCLC continues to work with the Province to implement recommendations from the independent review. As of February 2019, 11 recommendations have been completed.

Last Updated: April 05, 2019