Investigation and Enforcement activities

Modernization, transformation and integration

2022–23 saw the implementation of several important initiatives to drive the Bureau Excellence strategic priority. Bureau Excellence includes a new coaching and mentoring program for all new full-time Investigation and Enforcement Bureau (IEB) members, members on temporary assignments to IEB as well as members from outside police services coming into IEB as part of a joint forces operation. The program enables new members to become proficient in their chosen area of expertise in the Bureau through assignment of identified coaches and promotes a structured and firm foundation of understanding for new IEB members on all AGCO lines of business.

 

Eligibility and Major Investigations

The Enhanced Cannabis Application Pre-Screening Interviews continue to be essential in supporting the honesty and integrity of licensees, registrants and authorization holders and allow for immediate flagging of any criminal associations. In 2022, Eligibility and Major Investigations (EMI) conducted 641 cannabis-related investigations and noticed a significant decrease in the identification of problematic applications. This is attributed to the message being conveyed within the cannabis industry that the OPP was conducting thorough background investigations on applicants and entities.

In the igaming sector, IEB implemented EMI’s pre-screening igaming CEO interview questions to identify any possible risks associated with the AGCO registration of igaming entities. IEB continues to receive requests to conduct investigations on igaming service providers and suppliers. The igaming market continues to grow and evolve and many of the operators and suppliers are requesting amendments, hiring new personnel and applying for new licences.

The EMI igaming interview process continues to successfully identify problematic applicants. In some cases, this results in the withdrawal of applications by igaming applicants and entities.

 

Anti–money laundering

Anti–money laundering (AML) continues to be a key focus. IEB continues to proactively monitor, detect and deter money laundering from occurring within or related to legalized gaming activities in Ontario by continuing to:

1. lead and leverage the AGCO’s law enforcement and regulatory response to money laundering through sound processes and collaboration between all stakeholders to help protect the reputation of legalized gaming in Ontario, and
2. enhance training, investigative and analytical approaches, leveraging OPP and AGCO resources, partnerships and information sharing that emphasize the prevention, detection and reduction of potential money laundering activities in Ontario land-based gaming and igaming sites.

Anti–money laundering efforts are aligned with the Auditor General’s Value for Money Report which required IEB to gather evidence on the sources of funds for patrons identified with suspicious cash transactions, including conducting source-of-funds interviews, and updating the new data analytics system that was established to determine patrons’ risk ratings with all relevant data from all casinos.

A data-driven mindset is key to the IEB’s anti–money laundering approach. An analytical Suspicious Transaction Report (STR), dashboard tool that helps to identify and initiate investigations of individuals who pose risks of engaging in money laundering activities, has now been fully implemented. By automating the intake of all STRs generated at Ontario gaming sites, this tool has significantly reduced the number of manual processes. Thresholds and indicators are built within the dashboard to establish investigative priority and identify individuals, enabling IEB to allocate resources effectively and efficiently to determine if criminal investigations and/or regulatory recommendations are warranted. The STR analytical dashboard has over seven years of STR data from all gaming sites in the province of Ontario from 2016. An automated process has been implemented to obtain all future STRs from gaming sites on a monthly basis and working towards transitioning to weekly updates to the system in the future.

A STR/AML file assignment program called Significant Target Analysis Report (STAR) has been implemented across the province. This is a proactive police tool to identify High Priority Individuals (HPIs) for investigation. The analytical dashboard uses a catalog of tools to conduct a risk assessment on individuals based on Player Gaming Activity Reports obtained from the Ontario Lottery and Gaming Corporation (OLG), Police Risk Rating Scores, FINTRAC reports, police database searches and open-source searches.

The STAR approach proactively identifies HPIs that warrant investigations, which allows IEB to utilize resources effectively and efficiently. In addition, the STAR approach eliminates the administrative burden for frontline investigators and allows for more time to be spent on investigations. This is one of many enhanced strategies to reduce money laundering at land-based casinos in the province. In addition, IEB has developed a tracking system that allows for monitoring and automated follow-up capabilities of all STAR investigations assigned to ensure completion.

This proactive policing approach framework assists with intelligence-based decision making and next steps, such as recommendations for criminal or regulatory investigations, submissions for an AGCO Direction to Exclude, or providing cautions to OLG and its service provider partners.

Partnerships are key to the success of these AML programs. This year, a video was developed and implemented to raise awareness of AML investigative analytic processes among stakeholders, including the OLG, the OPP, the AGCO and FINTRAC. These partnerships were further supported by utilizing IEB’s AML Coordination Model, where dedicated OPP, OLG and AGCO analysts worked closely to query and analyze their respective agency’s data sets to openly share and discuss information and identify individuals and activities that pose AML risks.

 

Anti–human trafficking

The IEB Anti–Human Trafficking (AHT) Working Group collaborated with the OPP Anti–Human Trafficking Unit, Criminal Intelligence Service Ontario and municipal partners to proactively focus on AHT activities. The working group created a 2022 list of AHT police contacts from police jurisdictions across Ontario that house casinos and/or racetracks. The collaborative effort of this initiative allows investigators to quickly mobilize a multi-jurisdictional response to AHT investigations.

In October 2022, all IEB members received AHT training. Members of IEB have provided AHT training to service providers at all casino locations across the province. To date these IEB members have trained over 1,900 casino associates such as security, surveillance, and hotel staff. 

Table 29—Eligibility investigations

 

Table 30—Number of IEB investigations

Note: The launch of Ontario’s igaming market occurred on April 4, 2022, resulting in a significant increase in the number of Internet Gaming investigations that took place in 2022-23.

 

Table 31—Lottery-related investigations

 

Table 32—Occurrences at casinos and slot machine facilities