6. Minimizing Unlawful Activity Related to Gaming

6.1    Mechanisms shall be in place to reasonably identify and prevent unlawful activities related to lottery schemes.

Lottery-Specific Requirements – At a minimum, the Operator shall:

1. Conduct periodic risk assessments to determine the potential for unlawful activities, including money laundering, fraud, theft and cheat at play.
2. Ensure that all relevant individuals involved in the handling of lottery tickets, including production, distribution, activation, selling, validation, or redemption, remain current in the detection of techniques or methods (as appropriate) that may be used for the commission of unlawful activities related to lottery schemes.
3. Appropriately monitor transactions related  to,
   1. lottery tickets and analyze suspicious transactions for possible unlawful activity.

   2. sport and event betting to detect individuals attempting to circumvent the betting limit thresholds established in Standard 4.3.1(17).

4. Report suspicious behaviour, cheating at play and unlawful activities in accordance with the established notification matrix.

6.2    Not applicable to lottery sector.

6.3    The Operator shall have anti-money laundering policies and procedures in place.

Guidance: It is not intended for these mechanisms to include FINTRAC reporting, as the Proceeds of Crime (Money Laundering) and Terrorist Financing Act do not apply to lottery.