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Manitoba Liquor & Lotteries’ Anti-Money Laundering Program

Manitoba Liquor & Lotteries’ Anti-Money Laundering Program

As the Province of Manitoba’s legal authority to conduct and manage casino and gaming activity, and the designated reporting entity to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) for casinos, online gaming, and designated VLT sites, Manitoba Liquor & Lotteries takes its role in the detection, identification and reporting of potentially suspicious financial transactions very seriously.

Manitoba Liquor & Lotteries’ Anti-Money Laundering (AML) program is led by the Corporate Security team. To support the program and FINTRAC reporting obligations, the program has a designated Chief AML Compliance Officer and maintains specific internal polices and procedures, risk registers and AML Compliance training for management and staff working at the casinos as well as other employees who support the program. The AML program undergoes routine internal audits and is periodically audited by FINTRAC.

In Canada, casinos must fulfill specific obligations to help combat money laundering and terrorist activity financing within the country. To this end, Manitoba Liquor and Lotteries ensures all requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) are followed, including the establishment and maintenance of a compliance regime.

Please see the following Q&A regarding the AML program at Manitoba Liquor & Lotteries.

Money laundering is the process where the identity of money obtained from criminal activity is concealed in order to make it look legitimate. It is a global problem and its scope is significant.
FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) is the federal government agency responsible for the detection and prevention of money laundering and terrorist financing activities in Canada and abroad. FINTRAC has specific information collection and reporting obligations that casinos must fulfill to help combat money laundering and terrorist financing in Canada.
As Manitoba Liquor & Lotteries is the sole casino and gaming reporting entity to FINTRAC, it must report on Club Regent Casino and McPhillips Station Casino; First Nation Casinos (South Beach Casino & Resort, Sand Hills Casino, and Aseneskak Casino); Shark Club Gaming Centre, VLT sites with greater than 50 terminals, and online gaming (PlayNow.com).
These regulations apply when a reportable transaction occurs. This is when a person:
  • Wins single or multiple jackpots totalling $10,000 or more in a 24-hour period.
  • Redeems $10,000 or more in chips or slot tickets for cash, cheque or a combination of both in a 24-hour period.
  • Purchases $10,000 or more in chips or slot tickets in a 24-hour period.
  • Purchases $3,000 or more in chips or slot tickets in a single transaction.
  • Conducts a currency exchange that results in $3,000 CAD or greater.
  • Conducts a suspicious transaction at any dollar amount that may result in a report being sent to FINTRAC.

Note: To ensure compliance with these federal regulations, staff may ask a player for identification at lower dollar thresholds.

The following personal information is required:
  • Full name
  • Full address
  • Date of birth
  • Identification type, document number, and document expiration date
  • Occupation or business
  • Phone number (currently optional)
  • Place of employment/business location (currently optional)

Note: If there is more than one person associated to the reportable transaction, that person must also be completely identified and provide their occupation information as well.

The most common types of government issued identification used include:
  • A driver’s licence
  • A provincial / territorial government issued identification card
  • A passport
  • A secure certificate of Indian Status
  • A permanent resident card

Note: There may be additional options to identify a person on a reportable transaction. This decision will be made by casino management on a case-by-case basis.

Important: There may be a slight difference in the types of identification that is used to enter a casino vs. the type of identification that is required by FINTRAC.

The following identification will not be accepted:
  • Any expired identification.
  • Identification that appears to have been altered or that does not resemble the person conducting the transaction.
  • The Manitoba Liquor Control Commission (age of majority) cards. The cards have not been issued in several years. Most of these cards do not have an expiration date.
  • Provincial health cards are not to be used for identification purposes under these federal regulations.
  • Canadian Citizenship cards may not be accepted if they do not have an expiration date or if they are several years old.
Management/staff will explain to the person the need to provide identification on a reportable transaction. If a person still refuses to provide identification or occupation information, the following will occur:
  • A transaction may be declined, and the person refused service.
  • A person may be asked to leave the casino.
  • A large jackpot may be withheld until such time that appropriate identification and occupation is provided.
  • In some cases, a person may be banned from Winnipeg casinos, until he/she has provided appropriate identification and an occupation.
The federal regulations apply to the VLT sites in Manitoba that have more than 50 units in a single location.
PlayNow.com offers online casino games and a live casino option. The regulatory requirements on PlayNow.com are similar to online banking requirements and are slightly different from the regulatory requirements of a “brick and mortar” casino.

The most notable regulatory differences on PlayNow.com include identification requirements when a person creates an online account, or when a person conducts a FINTRAC reportable transaction.

For more information, please visit here.

The following privacy statements apply:
  • Manitoba Liquor & Lotteries is required to collect this information under the PCMLTFA and report it to FINTRAC.
  • Manitoba Liquor & Lotteries will collect the minimum amount of information necessary to fulfill these purposes.
  • Under Section 36 (1)(a) and (c) of the Freedom of Information and Protection of Privacy Act (FIPPA), Manitoba Liquor & Lotteries is permitted to collect personal information authorized under an enactment of Manitoba or of Canada, and for the purposes of law enforcement and crime prevention.
  • A person’s personal information is protected in accordance with the Privacy provisions of FIPPA.
  • Manitoba Liquor & Lotteries cannot use or disclose information without consent unless authorized or required to do so by FIPPA.

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