Administrative monetary penalty on British Columbia Lottery Corporation
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2025-08-28]
British Columbia Lottery Corporation, also operating as BCLC, a reporting entity in the casino sector, headquartered in Kamloops, British Columbia, was imposed an administrative monetary penalty of $1,075,000 on July 17, 2025, for committing 3 violations. The violations were found during the course of a compliance examination. British Columbia Lottery Corporation has appealed the decision to the Federal Court.
Nature of violation
- Violation #1
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Failure to submit suspicious transaction reports where there were reasonable grounds to suspect that transactions were related to a money laundering or terrorist activity financing offence – Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act), section 7.
British Columbia Lottery Corporation failed to submit 2 suspicious transaction reports where there were reasonable grounds to suspect that one or more transactions or attempted transactions were related to the commission or attempted commission of a money laundering or terrorist activity financing offence. FINTRAC’s examination further revealed gaps in the organization’s enhanced due diligence review process, and identified a number of money laundering and terrorist financing indicators that were not considered as part of British Columbia Lottery Corporation’s review of the high-risk patron whose transactional activity should have necessitated the submission of 2 suspicious transaction reports.
Violation #1 is classified by the regulations as a Very Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
- Violation #2
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Failure to develop and apply written compliance policies and procedures that are kept up to date, and, in the case of an entity are approved by a senior officer, section 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 156(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.
British Columbia Lottery Corporation failed to adequately document and implement procedures related to its obligations for high-risk clients namely in relation to conducting enhanced ongoing monitoring of business relationships to identity suspicious transactions, and conducting ongoing monitoring of business relationships to identify high-risk patrons. Specifically, British Columbia Lottery Corporation failed to adapt a frequency and depth of monitoring measures commensurate with a patron’s high-risk profile, which led to gaps in the timely review of transactions to detect suspicious transactions. Furthermore, British Columbia Lottery Corporation failed to document in its policies and procedures how a patron is determined high-risk, how high-risk activities conducted by patrons factor into the overall risk rating, and how it differentiates between low/moderate risk and high-risk patrons.
Violation #2 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
- Violation #3
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Failure to take the prescribed special measures that are required to be taken by a person or entity when the person or entity considers that the risk is high, or in the prescribed circumstances, the person or entity shall take the special measures referred to in the regulations, subsection 9.6(3) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 157 of the Regulations.
British Columbia Lottery Corporation failed to correctly identify a high-risk patron and apply enhanced due diligence measures. Specifically, due to the patron’s rate of play and the volume of funds, along with other factors, British Columbia Lottery Corporation should have identified the patron as high-risk and should have applied prescribed special measures, which if conducted, would have assisted the organization in analyzing, identifying, and reporting suspicious transaction reports in a timely manner.
Violation #3 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
Related link
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