Fight against money laundering

• LOTO-QUÉBEC’S ROLE

  As a federally regulated reporting entity, Loto-Québec has a role to play in the fight against money laundering and terrorist activity financing (ML/TF), even though it is only one of many players in the Canadian system involved in this fight. As part of this collective effort, the corporation works with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), its business partners and police forces.

  Loto-Québec takes its role and responsibilities very seriously in reducing the threat of money laundering at its casinos and gaming halls and on its gaming website. It is committed to fighting ML/TF, in keeping with its mission and values.

  The corporation stays abreast of best practices in the fight against ML/TF to promote order and moderation, as laid out in its mission statement.

• WHAT IS MONEY LAUNDERING?

  Money laundering involves concealing the source of funds or goods derived from criminal activity.

   

• LOTO-QUÉBEC’S COMPLIANCE PROGRAM

  Loto-Québec implemented a compliance program under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The purpose of this program is to ensure that Loto-Québec, like all other reporting entities that the Act applies to, contributes to the fight against ML/TF and complies with all its regulatory requirements, including the following:

  • Verifying customers’ identities:
    • When opening an account (in this case, the verification includes taking reasonable measures to determine whether the customer trying to open an account is a politically exposed person (PEP), a head of an international organization (HIO), or a person intimately linked to a PEP or an HIO)
    • When receiving an amount of $10,000 or more in cash or making a disbursement worth $10,000 or more, receiving funds valued at $3,000 or more, making a foreign currency exchange transaction of $3,000 or more (in Canadian dollars) and initiating an electronic funds transfer of $1,000 or more or when sending funds to the beneficiary of an electronic funds transfer
    • When reporting a suspicious transaction, if verification is possible

  • Reporting to FINTRAC:
    • Any reception of $10,000 or more in cash and any disbursement to a customer worth $10,000 or more
    • Any suspicious transaction or attempted suspicious transaction when there are reasonable grounds to suspect that it is related to money laundering or a sanctions evasion offence
    • Any goods (including an account or money) owned or controlled by a casino that may belong to a terrorist group
  • Establishing policies that must be complied with across the corporation
  • Training all customer-facing staff as well as any person in charge of monitoring the compliance program
  • Assessing the risks related to the corporation’s operations and customers, thus ensuring customers, especially those whose behaviour poses a high risk, are continuously monitored
  • Reviewing its compliance program every two years
• EMPLOYEES’ INVOLVEMENT IN THE FIGHT AGAINST MONEY LAUNDERING

  To implement its compliance program, Loto-Québec has created a team of certified specialists, intelligence analysts and lawyers supported by the security teams.

  Casino, gaming hall and online gaming employees take training courses that include refresher sessions when regulatory changes are made. In total, over 3,500 staff members are trained to recognize the increasingly sophisticated methods used by organized crime and detect any suspicious activity to help in the fight against ML/TF.

  The corporation has also created multi-sector committees to ensure a continuous flow of information and enhance and standardize its practices.

• COLLABORATION WITH POLICE FORCES

  Loto-Québec provides police forces and other authorities responsible for enforcing the Act with any information they request. It also implements all the measures the authorities require, including those that apply to individuals they consider persons of interest.

• COMPLIANCE REVIEW

  Loto-Québec reviews its compliance program at least every two years. Every review is an opportunity for the corporation to assess the robustness of the measures in place, implement the required corrections, if applicable, and make improvements to strengthen the program.

  Loto-Québec worked with the government of Québec to set up measures to meet the recommendations of the independent audit on money laundering and loan sharking in Québec casinos and gaming halls. Several audit report recommendations were already part of Loto-Québec's actions to improve its practices.

• PROCEDURES IMPLEMENTED FOR CASINOS, GAMING HALLS AND ONLINE GAMING

  The specific procedures applied to all customers at casinos and gaming halls and online include the following general rules:

  • A cheque could be issued to a customer only once it is confirmed that they won money while gaming.
  • The inventory of chips in circulation is monitored, allowing for discrepancies to be detected.
  • A monitoring process aimed at detecting instances where money is exchanged between individuals is carried out to prevent loan sharking in particular.
  • A customer’s identity is verified per FINTRAC requirements before they open their online gaming account.
  • The identity of a customer from whom $3,000 or more are received in one transaction is verified per FINTRAC requirements. Moreover, the source of the money and goods (chips) could be checked if the corporation deems it necessary.
  • Special measures apply to mitigate the risk level of transactions and business relationships deemed high-risk.
  • A preventive measure is in place to oversee the circulation of high-denomination chips outside the casino: customers must go to the casino cash desk to exchange any chip with a denomination of $500 or higher in their possession before leaving the gaming location.
  • A new security measure stemming from an amendment to the Rules respecting conditions governing admission of the public, maintenance of public order and safety of persons in State casinos—which the Régie des alcools, des courses et des jeux is responsible for enforcing—was adopted. This measure, which complies with Loto‑Québec’s general guidelines on integrity, refuses admission to casinos and gaming halls to a person who has been convicted of specific criminal offences in the last five years, including those that interfere with the integrity of State casino activities or undermine public trust in their integrity.
• SUBMIT A REPORT

  Loto-Québec aims to maintain the highest standards with respect to the independence, safety and security of its employees to prevent and detect behaviours that could pose a risk to casino and gaming hall operational integrity.

  Loto-Québec calls on ClearView to fulfill this commitment. The company confidentially receives and processes reports on:

  • Any situation occurring at a casino or gaming hall where conduct is observed that could undermine the integrity of Loto-Québec’s operations or be in violation of applicable laws and regulations
  • Any action by an employee or service provider that could be considered unethical

   

  Casino and gaming hall customers can submit a report to ClearView by calling 1-866-734-7728 toll-free or going to clearviewconnects.com.

  This service is not intended to receive complaints or comments about customer service or dissatisfaction with a visit to one of our gaming locations or to question the merits of any implemented policy or procedure. In such cases, questions and comments must be addressed to the relevant gaming location’s customer service team.

• Collaboration with FINTRAC

  The role of FINTRAC

  FINTRAC, the Financial Transactions and Reports Analysis Centre of Canada, is Canada’s financial intelligence unit. Its mandate is to facilitate the detection, prevention, and deterrence of ML/TF. Through its work with domestic and international partners, it contributes to the public safety of Canadians and helps protect the integrity of Canada’s financial system.

  FINTRAC discloses tactical financial intelligence to the appropriate federal, provincial, and municipal investigative and intelligence organizations. These organizations include Canadian police forces, the Canadian Security Intelligence Service (CSIS), the Canada Border Services Agency (CBSA), the Canada Revenue Agency (CRA), and provincial and territorial securities commissions.

  The financial intelligence that FINTRAC discloses to these organizations comes from various business entities, including banks, money services businesses, casinos, dealers in precious metals and stones and real estate brokers. By law, these entities are required to report to FINTRAC, through secure and confidential means, when there are reasonable grounds to suspect that a financial transaction is connected to the commission or attempted commission of an ML/TF offence or when the reporting threshold for a transaction has been met. Every year, FINTRAC receives millions of transaction reports from over 24,000 reporting entities to which the law applies.

  Collaborating with FINTRAC

  As a federally regulated reporting entity, Loto-Québec has a role to play in the fight against ML/TF, even though it is only one of many players in the Canadian system involved in this fight. As part of this collective effort, the corporation works with FINTRAC, its business partners and police forces. Its role is to collect information related to its customers and various types of transactions at its gaming locations, including large cash transactions and suspicious transactions, and to report this information to FINTRAC in accordance with the rules in force. It is then up to FINTRAC to collect, analyze and disclose this information to support the detection, prevention and deterrence of money laundering and terrorist activity financing in Canada and abroad.

  Over the past few years, Loto-Québec has joined this collective effort by submitting reports to FINTRAC in accordance with the law:

  Large cash transactions reported by Loto-Québec to FINTRAC

  2024-2025	6,070
  2023-2024	6,249
  2022-2023	7,029

   

  Casino disbursements reported by Loto-Québec to FINTRAC

  2024-2025	20,359
  2023-2024	19,038
  2022-2023	19,229

   

  Suspicious transactions reported by Loto-Québec to FINTRAC

  2024-2025	555
  2023-2024	822
  2022-2023	609