Administrative monetary penalty on Atlantic Lottery Corporation Inc.
[2026-07-09]
Atlantic Lottery Corporation Inc., also operating as Atlantic Lottery, a reporting entity in the casino sector, headquartered in Moncton, New Brunswick, was imposed an administrative monetary penalty of $212,025 on May 29, 2026, for committing 3 violations. The violations were found during the course of a compliance examination. Atlantic Lottery Corporation Inc. has paid the administrative monetary penalty in full and the case is closed.
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, section 7
Atlantic Lottery failed to submit one suspicious transaction report where there were reasonable grounds to suspect that one or more transactions were related to the commission or attempted commission of a money laundering or terrorist activity financing offence. FINTRAC’s examination identified transactions conducted by a client where numerous money laundering and terrorist financing indicators were present. These indicators included:
- Funds transferred in and out of an account on the same day or within a relatively short period of time;
- Client avoids contact with reporting entity employees;
- Atypical transfers by a client on an in-and-out basis, or other methods of moving funds quickly, such as cash deposit followed immediately by a wire transfer of the funds out; and
- Insufficient explanation for the source of funds.
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 Proceeds of Crime (Money Laundering) and Terrorist Financing 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 – 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)(b)
During the examination period, FINTRAC determined that the policies and procedures implemented by Atlantic Lottery to fulfill its compliance obligations were inadequate and incomplete. Atlantic Lottery’s delegation of compliance responsibilities to its casino site operators led to inconsistent application of specific obligations across its operations. Atlantic Lottery’s obligations, as detailed below, were implemented independently at each site rather than being applied adequately and consistently across the organization as a whole.
Specifically, Atlantic Lottery’s policies and procedures did not include requirements related to ministerial directives and the requirements related to verifying the identity of persons and entities were incomplete. Further, FINTRAC found that Atlantic Lottery’s policies and procedures for reporting suspicious transactions, as well as for reporting the receipt of cash and casino disbursements under the 24-hour rule, were inadequate as they were missing key regulatory requirements and were not consistently applied in practice.
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 Proceeds of Crime (Money Laundering) and Terrorist Financing 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 assess and document the risk 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) of the Act and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c)
FINTRAC determined that Atlantic Lottery failed to complete and document an enterprise-level risk assessment of money laundering and terrorist financing risks based on its overall business activities, clients and business relationships, as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations.
Although Atlantic Lottery’s individual casino site operators documented their own risk assessment, FINTRAC determined these assessments were missing key elements and did not adequately consider all prescribed factors, as required under the Act and associated Regulations.
Violation #3 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
Related link
- Date Modified: