FINTRAC penalizes Canadian National Exhibition Casino

On September 4, 2025, the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) announced a significant enforcement against the Canadian National Exhibition Casino (“CNE Casino”) in Toronto. An administrative monetary penalty (“AMP”) of $199,000 was imposed on July 11, 2025, for non-compliance with Canada’s anti-money laundering and anti-terrorist financing laws (the “Penalty”). FINTRAC is authorized to issue an AMP and serve a notice of violation when it has reasonable grounds to believe that a reporting entity (“RE”) has violated a requirement of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“Act”) or its associated Regulations.

The violations

Under the Act, CNE Casino, as an RE, is required to keep certain records, identify clients, maintain a compliance regime, and report certain financial transactions to FINTRAC, including international electronic funds transfers, large cash transactions, large virtual currency transactions, and suspicious transactions. However, FINTRAC found CNE Casino committed two administrative violations:

• failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors; and
• failure to institute and document the prescribed review.

The Act and Regulations mandate REs to assess and document money laundering, terrorist financing, or sanctions evasion risks using prescribed factors like clients, business relationships, products, correspondent banking relationships, products, services, delivery channels, and geographic location of the RE’s activities. While CNE Casino staff stated high-risk transactions would be reported to the Compliance Officer, FINTRAC found that this reporting process did not meet the legislative requirement for a documented, risk-based assessment incorporating prescribed factors.  

The prescribed review refers to the mandatory two-year effectiveness review and plan mandated by the Act, requiring an RE to review its policies and procedures, risk assessment, and ongoing compliance and training program and plan. Despite CNE Casino claiming an annual review was conducted, FINTRAC found no documentation to verify this, resulting in a breach of the Act’s requirements.

As a result, FINTRAC classified both violations as serious, which justified the imposition of AMPs.

The AMPs

FINTRAC emphasizes that AMPs are necessary to encourage ongoing compliance. The reputational risk is also significant, with the public notice of an AMP remaining posted on FINTRAC’s website for five years.

AMPs are typically set within specific ranges—from minor to very serious—with penalties for a serious violation reaching up to $100,000 per violation for an RE. The two serious violations against CNE Casino resulted in the near-maximum combined penalty of $199,000. CNE Casino’s corrective actions led FINTRAC to reduce each violation by $500.

In calculating the Penalty, FINTRAC considers three key factors, set out in the Act and its Regulations:

• the non-punitive purpose of penalties (to encourage compliance, not to punish);
• the degree of harm caused by the violations; and
• the reporting entity’s past compliance history.

CNE Casino has appealed the decision to the Federal Court, denying any violation of the Act or Regulations. However, it may take months before the case progresses.

A shift towards stricter enforcement

The CNE Casino case reflects a broader shift toward stricter enforcement by FINTRAC. In 2024-2025, FINTRAC issued 23 Notices of Violation of non-compliance to businesses—the largest number in one year in their history, totaling more than $25 million. Since receiving authority to impose AMPs in 2008, FINTRAC has issued more than 150 penalties across most business sectors.

Recent casino sector enforcement includes:

• British Columbia Lottery Corporation (BCLC)—FINTRAC issued an AMP of $1,075,000 on July 17, 2025, for three violations (appealed to Federal Court); and
• Loto-Québec—FINTRAC issued an AMP of $147,015 on February 28, 2020, for three violations (case now closed).

Together with FINTRAC’s revised AMP policy, touched on in our last Finance Alert, and the rise in both the frequency and size of penalties, these cases demonstrate a shift toward stricter enforcement.

Looking ahead

REs should review their compliance programs in light of these developments. They should also monitor the progress of Bill C-2, also known as the Strong Borders Act,which proposes to increase maximum AMP amounts.

If you believe your business may be impacted, please contact a member of our Financial Services or Compliance teams for assistance.