Administrative monetary penalty on Saskatchewan Indian Gaming Authority
[2025-09-12]
Saskatchewan Indian Gaming Authority, also operating as SIGA, was imposed an administrative monetary penalty of $1,175,000 on August 28, 2025, for committing 3 violations. The violations were found during the course of a compliance examination.
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.
FINTRAC determined that SIGA failed to submit 4 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 concluded that SIGA was aware of sufficient relevant information, coupled with the presence of multiple money laundering indicators of suspicious activity necessary, to meet the reasonable grounds to suspect threshold for reporting suspicious transactions. These indicators included: client exhibits knowledge of reporting thresholds; the transactional activity (level or volume) is inconsistent with the client's apparent financial standing, their usual pattern of activities or occupational information; transactions involve persons identified by the media, law enforcement and/or intelligence agencies as being linked to criminal activities; and large and/or rapid movement of funds not commensurate with the client's financial profile. These indicators demonstrate that SIGA had reasonable grounds to suspect that the transactions conducted by the patrons were in line with those related to the commission or attempted commission of a money laundering or terrorist financing offence.
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 report suspicious transactions with the prescribed information – section 7 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and subsection 9(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations.
FINTRAC determined that, in 3 instances, SIGA did not include any money laundering or terrorist financing indicators in the “Details of suspicion” section of the suspicious transactions reports that it submitted. Failing to submit reports in accordance with the guidelines prepared by FINTRAC may prevent FINTRAC from efficiently analyzing information and may even render the information unusable for analysis.
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 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 – subsection 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.
FINTRAC determined that SIGA had inadequate policies and procedures for the ongoing monitoring of high-risk and extreme high-risk patrons. SIGA failed to properly assess the risk for all of its patrons. In 41 out of 100 instances reviewed, SIGA listed its patrons’ risk level as “none”. In accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, a casino is required to risk assess a patron when it enters into a business relationship. When this business relationship is established, ongoing monitoring requirements are triggered, where a casino must review all information obtained about the patron with whom it has a business relationship, including the original risk assessment. Since SIGA did not have an original risk assessment (“none”), it failed to conduct its ongoing monitoring and its business relationship requirements.
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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