FINTRAC imposes administrative monetary penalty on British Columbia Lottery Corporation

On August 28, 2025, the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) published a public notice of an Administrative Monetary Penalty (“AMP”) it levied on the British Columbia Lottery Corporation (the “BCLC”) in the amount of $1,075,000. The BCLC is a Canadian Crown corporation, meaning it is a wholly owned by the Province of British Columbia and structured like a private/independent company. The BCLC is responsible for managing all legal gambling activities in the province of British Columbia, including lottery games, casinos, and online gambling. The BCLC was found non-compliant with Part 1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the “PCMLTFA”) and its associated Regulations.

Following a compliance examination, the AMP was imposed on July 17, 2025, publicly confirmed on August 28, 2025, and is now the subject of an appeal. This dispute began on March 20, 2025, when FINTRAC first issued the BCLC a notice of violation for administrative deficiencies. The BCLC reviewed the findings and submitted counterarguments; however, FINTRAC upheld its decision, resulting in the imposition and public confirmation of the AMP. The BCLC has appealed the decision to the Federal Court. If the Federal Court decides to hear the appeal, the decision could establish a precedent for how gaming operators and other reporting entities challenge AMP’s imposed by FINTRAC.

Nature of the violations

Here is a look at the nature of each of the BCLC’s three administrative violations:

Violation #1 – Failure to report suspicious transactions

BCLC failed to file two suspicious transaction reports despite having reasonable grounds to suspect links to money laundering or terrorist financing. FINTRAC found gaps in enhanced due diligence and that key risk indicators were overlooked in assessing a high-risk patron. According to court documents, a single high-stakes slot machine player is at the center of violation. This is classified by the regulations a Very Serious violation.

Violation #2 – Failure to develop and apply policies and procedures for high-risk clients

BCLC did not maintain up-to-date, senior officer–approved compliance policies and procedures. It lacked clear documentation on identifying high-risk patrons, monitoring them appropriately, and distinguishing between different risk levels, leading to failures in detecting suspicious activity. This is classified by the regulations a Serious violation.

Violation #3 – Failure to take special measures for high-risk clients

BCLC failed to apply required enhanced due diligence for a high-risk patron, despite clear red flags such as high transaction volume and rate of play. As a result, it missed opportunities to identify and report suspicious transactions in a timely manner. This is classified by the regulations a Serious violation.

Key takeaways

The AMP imposed on the BCLC underscores FINTRAC’s commitment to enforcing Canada’s anti-money laundering and anti-terrorist financing laws. This action highlights the critical importance of compliance, particularly in high-risk sectors like casinos, and serves as a reminder that all regulated entities must uphold their legal obligations to detect and report suspicious financial activity.

If you are concerned that your business may be impacted, contact a member of our Financial Services or Compliance team for assistance.