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Too much at stake

Canada’s new anti-money laundering law brings new challenges for casinos


To ensure that Canada keeps pace with the leading countries in preventing money laundering and terrorist financing, Canadian legislators have made significant legislative and regulatory changes. What does this mean to Canadian casinos, which are potential targets for money launderers? The recent amendments to the Proceeds of Crime [Money Laundering] and Terrorist Financing Act (PCMLTFA) are tightening controls on the way money changes hands in Canada. Casinos were given a very short time frame to implement significant changes in their internal controls.

The key amendments applicable to casinos affect reporting, record keeping and client identification. Casinos must report suspicious transactions no matter if the transactions were completed or just attempted. The amendments require casinos to keep a transaction ticket for every foreign currency exchange, regardless of the amount, which brings them in line with other financial institutions conducting foreign exchange transactions. Under the new gaming legislation, casinos are also required to keep on record the birth date of individual clients who open accounts.

The penalties for non-compliance can go up to $2 million in fines, and FINTRAC, the Financial Transactions and Reports Analysis Centre, has been given greater flexibility to levy fines for less serious contraventions of the Act. Compliance, however, is only the beginning. In fact, a lot more is at risk: a business’s reputation, and even its gaming licence, as well as the political fortunes of provincial government parties who regulate gaming. With so much at stake, the stakeholders must act now.

To help the gaming industry stay on the right side of the law, Deloitte has developed "This is no game," a publication highlighting the changes in the legislation and necessary actions.

Deloitte Image Read   This is no game  


What cards are you holding?

Under the amended law, every anti-money laundering compliance program must include a money laundering and terrorist financing risk assessment. High-risk areas must be identified and monitored on an ongoing basis.

Here are some questions to consider:

  • Have you developed a comprehensive program to combat money laundering and terrorist financing?
  • Are you paying enough attention to customer identification including non face-to-face relationships and transactions?
  • Are you equipped to detect and report unusual or suspicious transactions?
  • Have you completed a money laundering and terrorist financing risk assessment appropriate to each of your business relationships, products, delivery channels and geographic areas of operation?
  • Will you use an independent party to perform an anti-money laundering and anti-terrorist financing policy and procedures compliance review? Do they have sufficient expertise?
  • Have you maintained continuity of data systems and records? Can you retrieve and use data as old as the oldest transaction when requested by your regulator?

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