724 THE ADVOCATE
VOL. 76 PART 5 SEPTEMBER 2018
through new procedures that require service providers to gather detailed
information on the source of a player’s funds for all transactions of $10,000
or more. BCLC’s response included expanding the types of transactions to
which a source of funds declaration applies and requiring service providers
to record more detailed information about a customer’s source of funds. If
a customer does not provide the required information, gives suspicious
information or does not sign the source of funds declaration form, then the
service provider must refuse the transaction. This policy has contributed to
a steep decline in suspicious cash transactions in casinos.
The Gaming Policy and Enforcement Branch (“GPEB”) is also executing
a plan to increase the regulator’s presence at high-volume casinos, consistent
with Dr. German’s second interim recommendation that government
regulators have an enhanced presence at large, high-volume facilities in the
In March 2018 Dr. German provided a further interim recommendation.
He recommended that the province make representations to the House of
Commons Standing Committee on Finance with respect to a public consultation
underway regarding amendments to the Proceeds of Crime (Money
Laundering) and Terrorist Financing Act, and on March 27, 2018, I appeared
before the federal finance committee to discuss the work underway to fight
money laundering in B.C.
In addition to taking positive action to review and address issues of
money laundering in B.C. casinos, it was important to recognize that the
revenue obtained by government from the gambling industry may be
impacted in undertaking the review and in taking subsequent action. Revenue
obtained by government from the gambling industry funds numerous
government programs. This includes funding programs focused on social
welfare, education and health. However, we have a responsibility to ensure
that processes are set up to minimize the possibility that these revenue
streams originate from criminal activity. In the expectation that the steps
and actions to be taken to combat money laundering may financially
impact government, our 2018 budget included a projection that gambling
revenues could decrease by approximately $30 million as a result of tackling
money laundering, and steps were taken to ensure programs funded by
gaming revenues would not face a reduction in their gaming grants.
On June 27, 2018 I publicly released Dr. German’s report entitled Dirty Money.
This report indicates that “for many years certain Lower Mainland casinos
unwittingly served as laundromats for the proceeds of organized crime” and