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, even though it is just one among the many stakeholders in the Canadian system that are involved in this fight. As part of this collective effort, the Corporation collaborates 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 when it comes to reducing the threat of money laundering in its casinos and gaming halls, as well as on its online gaming platform. It is committed to the fight against money laundering, a commitment that is in line with its mission and values.

  In an effort to promote good order and moderation as stated in its mission, the Corporation is constantly on the lookout for best practices in the fight against money laundering.

   

• WHAT IS MONEY LAUNDERING?

  Money laundering is a process that consists of concealing the source of money or assets that are 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. This program seeks to ensure that, like other reporting entities governed by the Act, the Corporation contributes to the fight against money laundering and complies with all of the related regulatory requirements, including the following:

  • Reporting to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC):
    • Any receipt of $10,000 or more in cash and any disbursement of $10,000 or more made to a client,
    • Any suspicious transaction or attempted transaction when there are reasonable grounds to suspect that a transaction is related to money laundering;
  • Establishing policies that must be followed throughout the Corporation;
  • Training all staff members who are in contact with clients and all those responsible for implementing the compliance program.
  • Evaluating the risks associated with the Corporation’s activities and clients, thereby ensuring ongoing monitoring of clients, particularly among those identified as posing a high risk;
  • Reviewing its compliance program every two years.
• EMPLOYEES’ INVOLVEMENT IN THE FIGHT AGAINST MONEY LAUNDERING

  Loto-Québec has assigned a team to implement its compliance program. The team is comprised of certified specialists, intelligence analysts and lawyers, and is supported by the security teams.

  Employees of casinos, gaming halls and online gaming complete training which includes refresher courses, particularly when regulatory changes are made. Over 3,500 employees are therefore trained to detect suspicious situations and contribute to the fight against money laundering.  

  Multi-sectoral committees are also established to ensure continuous information sharing, as well as to enhance and standardize practices within the Corporation.

• COLLABORATION WITH POLICE FORCES

  Loto-Québec provides all information requested by police and other law enforcement authorities. It also implements all measures required by these authorities, including those applicable to individuals whom authorities consider to be subjects of interest.

• COMPLIANCE REVIEW

  Loto-Québec’s compliance program is reviewed periodically.

  Each review is an opportunity for the Corporation to question the robustness of the measures in place and make the necessary improvements to strengthen its program.  

  In collaboration with the Québec Government, Loto-Québec is currently developing measures to respond to the recommendations arising from the independent audit [in French only] on the phenomenon of money laundering and loan sharking in Quebec casinos and gaming halls. Several of the recommendations contained in the report are in line with the continued action that Loto-Québec has already undertaken to improve its practices.

  Consult the summary report [in French only, PDF – 2.04 MB]

• PROCEDURES IMPLEMENTED FOR CASINOS, GAMING HALLS AND ONLINE GAMING

  The specific procedures which apply to clients of casinos, gaming halls and online gaming include the following general rules:

  • A cheque is issued to a client upon confirmation of a win during their gaming session;
  • The inventory of chips in circulation is monitored, which allows any discrepancies to be identified;
  • Monitoring is conducted to detect situations where money is exchanged between individuals in an effort to prevent loan sharking, etc.;
  • A client’s identity is verified prior to their online gaming account being opened. Among other things, this verification process requires the presentation of photo ID or a credit report analysis;
  •  Every receipt of $3,000 or more in funds in a single transaction is subject to identity verifications. Moreover, the source of the money and goods (chips) could be checked if the corporation deems it necessary;
  • Special measures are applied to mitigate the risk level of transactions and business relationships deemed high risk.
• SUBMIT A REPORT

  Loto-Québec wishes to maintain the highest standards with respect to the independence, safety and security of its employees, in order to prevent and detect behaviour that could pose a risk to the integrity of operations in its casinos and gaming halls.

  To fulfil this commitment, Loto-Québec called on ClearView, a company that receives and handles, in a confidential manner, reports relating to:

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

   

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

  This service is not intended to receive complaints or comments related to customer service or dissatisfaction with a visit to one of our establishments, nor is it intended to question the merits of any policy or procedure in place. In such cases, please direct your questions and comments to the customer service team of the establishment in question.

• Collaboration with FINTRAC

   

  Role of the Financial Transactions and Reports Analysis Centre of Canada

  The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada’s financial intelligence unit. Its mandate is to facilitate the detection, prevention, and deterrence of money laundering and the financing of terrorist activities. 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 investigative and intelligence organizations at the federal, provincial, and municipal levels. Such organizations include the 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, among others.

  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 securities dealers. 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 related to the commission or attempted commission of money laundering or terrorist activity financing offence, or when the threshold for reporting a transaction has been met. Every year, FINTRAC receives millions of transaction reports from over 30,000 reporting entities to which the law applies.

   

  Collaboration with FINTRAC

  As a reporting entity covered by the federal legislation, Loto-Québec has a role to play in the fight against money laundering, although it is only one of many players in the Canadian system involved in this fight. As part of this collective effort, the Corporation is working with FINTRAC, its business partners and the police. Its role is to collect information related to its patrons 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 regulations 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 last years, Loto-Québec contributed to the collective effort to fight money laundering by submitting reports to FINTRAC, in accordance with the law:

  Large cash transactions reported by Loto-Québec to FINTRAC

  2020-2021	1,036
  2019-2020	4,660
  2018-2019	5,041
  2017-2018	5,540

   

  Suspicious transactions reported by Loto-Québec to FINTRAC

  2020-2021	206
  2019-2020	395
  2018-2019	328
  2017-2018	343

   

  Loto-Québec takes its role and responsibilities very seriously when it comes to reducing the threat of money laundering at its casinos and gaming halls and on its gaming website. In keeping with its mission and values, it is committed to fighting money laundering.

  Knowing that this is an ongoing challenge, the Corporation stays abreast of the best anti-money laundering practices.

  Loto-Québec conducts a compliance review of its anti-money laundering program at least every two years and ensures that corrective measures and improvements are implemented. It also trains its employees to meet the complex challenges posed by organized crime, whose tactics are always evolving.