Administrative monetary penalty on CNE Casino
[2025-09-04]
Canadian National Exhibition Association, also operating as Canadian National Exhibition Casino (CNE Casino), a casino in Toronto, Ontario, was imposed an administrative monetary penalty of $199,000 on July 11, 2025, for committing 2 violations. The violations were found during the course of a compliance examination. CNE Casino has appealed the decision to the Federal Court.
Nature of violation
- Violation #1
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Failure of a person or entity to assess and document the risk of a money laundering offence or a terrorist activity financing offence as referred to in subsection 9.6(2) of the Act, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c).
FINTRAC determined that CNE Casino failed to assess and document the money laundering and terrorist financing risks related to its products, services and delivery channels, clients and business relationships, geographic locations, affiliates and subsidiaries, and any other relevant factors. Specifically, CNE Casino indicated that staff would report high-risk transactions to its Compliance Officer; however, this process does not meet the legislative requirement for a documented, risk-based assessment. A risk-based assessment helps identify, document and mitigate potential risks considering all prescribed factors, as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations.
Violation #1 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 #2
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Failure of a person or entity to institute and document the prescribed review – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(f).
FINTRAC determined that CNE Casino failed to conduct a review of its compliance program to test the effectiveness of its policies and procedures, risk assessment and training program. CNE indicated that an annual review was conducted; however, no documentation was available to confirm that the prescribed review took place.
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.
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