Minimizing Unlawful Activity Related to Gaming

The overall intent of this theme is to protect the public interest and public safety by ensuring that unlawful and criminal activity does not take place in gaming in Ontario.

The identified regulatory risks under this theme are: 

  • Gaming used as a vehicle for money laundering 
  • Gaming used as a vehicle for fraud or theft 
  • Internal theft is occurring 
  • Cheat at play materializes within the gaming environment 

6.01 Mechanisms shall be in place to reasonably identify and prevent unlawful activities at the gaming site.

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 operation, supervision or monitoring of the gaming site shall remain current in the identification of techniques or methods that may be used for the commission of crimes at the gaming site.
  3. Appropriately monitor player and employee transactions, including the ongoing analysis of incident reports and suspicious transactions for possible unlawful activity.
  4. Report suspicious behaviour, cheating at play and unlawful activities in accordance with the established notification matrix.

6.02  Anti-money laundering policies and procedures to support obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) shall be implemented and enforced.

Requirements – At a minimum:

  1. Copies of all reports filed with FINTRAC and supporting records shall be made available to the Registrar in accordance with the established notification matrix.
  2. Operators shall ensure their anti-money laundering internal controls align with those of the designated reporting entity under the PCMLTFA.

6.03  Reasonable measures shall be in place to identify and prevent suspected money laundering activities in the gaming site.

Requirements – At a minimum, the Operator shall:

  1. Implement policies, procedures and controls that specify times and situations, based on the assessment of risk, where the Operator will ascertain and reasonably corroborate a player’s source of funds.
  2. Implement risk-based policies and procedures that provide for escalating measures to deal with players who engage in behaviour that is consistent with money laundering indicators, including the refusal of transactions or exclusion of the player.
  3. Ensure that mechanisms are in place to share information, in a lawful manner, about high-risk or suspicious activities with other Operators which may also be subject to similar activity.