The following highlights the techniques observed by FINTRAC in 2008-2009 which suggest the use refining as part of money laundering activity: Although this report has focused on money laundering activity in Canadian casinos, often the overall money laundering process includes transactions in more than one sector. Casinos may not be privy to these transactions, and so this report has described how certain casino transactions may be part of larger money laundering schemes online slots canada health, in an effort to help casino staff identify suspicious transactions that should be reported to FINTRAC. Business Associated to Drug Cases, Organized Crime and Fraud Cases Through this paper FINTRAC seeks to address questions about money laundering (ML) that are unique to the Canadian casino sector and have been observed in our analysis of financial transactions in casinos. It should be noted that certain money laundering/ terrorist activity financing schemes can involve the use of different sectors and/or services at the same time. For example, in 33% of all 2008-2009 cases, financial transactions were conducted through both financial institutions and MSBs. Similarly, 17% of 2008-2009 cases contained financial transactions conducted through both financial institutions and casinos. Finally, 6% of all cases involved suspicious financial transactions conducted through all three sectors (i.e. financial institutions, MSBs and casinos). The following highlights the techniques observed by FINTRAC in 2008-2009 which suggest the use of credit cards as part of money laundering activity: Use of Casino Value Instrument The following types of businesses were found to be associated to all types of cases. that is, they were suspected to be involved in laundering illicit proceeds or acting as vehicles for terrorist financing: Front money accounts are more widely available in Canadian casinos, and allow a customer to deposit money with the casino, which they can draw upon for gaming purposes. This service not only provides a measure of convenience for the customer, but provides increased security, as customers do not have to arrive at or depart the casino carrying large amounts of cash with them.
At least one provincial gaming authority in Canada has prohibited the direct exchange of small denomination bills to large denomination bills through its cashier windows. Refining through the use of TITO tickets is roulette real money exchange, however, less obvious. The use of TITO tickets in money laundering activity is addressed in the fourth section of the report, which discusses the risks associated with this casino service. This FINTRAC report is the first of its kind for the casino sector and was made possible through collaboration between FINTRAC and certain Canadian gaming operators, including Loto-QuГ©bec, the Ontario Lottery and Gaming Corporation and the British Columbia Lottery Corporation. The discussions between the casino sector and the Centre have guided the subjects that are examined in this report. This case also highlights the use of casino value instruments as a method of money laundering, although in this example, different techniques are used. Illicit funds are placed in the individual's line of credit account through the deposit of cheques. The individual layered transactions by purchasing casino chips, and redeeming the chips for casino cheques, which are deposited to the individual's line of credit account and a personal account. The individual also possibly engaged in layering activity by leaving the casino with chips, and passing the chips to an organized crime figure, who continued the layering process by redeeming the chips for a casino cheque. Additional businesses, listed here in no particular order, were found to be associated to both fraud and drug/organized crime cases and included the following: When a series of money laundering schemes appear to be constructed in a similar fashion or using the same methods pokies online insurance, the similar schemes are generally classified as a typology. A method refers to the particular procedure or series of actions used to carry out money laundering activity and normally involves a number of different techniques. A technique is the particular action or way that the money laundering activity is carried out. Footnote 7 In cases where the credit card has not been stolen or fraudulently obtained, a money launderer may seek to purchase casino value instruments using a credit card, obtain a casino cheque for the majority of the value of the chips purchased, and use illicit funds to pay down the credit card balance. The following highlights the techniques observed by FINTRAC in 2008-2009 which suggest the use currency exchange(s) as part of money laundering activity: As briefly mentioned in the section discussing the refining method, TITO is a relatively new system for slot machines and Video Lottery Terminals (VLTs) that is designed to replace coins or tokens. Traditionally, slot machine jackpots were paid by coins or tokens falling into the slot tray, which the customer would then collect in buckets. TITO replaces the coins with a slip of paper, or "ticket," that contains a unique bar code. The ticket can be fed into other slot machines to continue play, scanned at cashier stations for a cheque or cash, or redeemed at an automated redemption machine. Footnote 6 Figures included in the table do not total 100% given that some cases involve multiple predicate offences. Back Money Laundering Method Footnote 1 Annual case reviews provide a complete picture of the trends and activities related to ML/TF within that year. Every case review better positions FINTRAC to be able to identify Canadian trends in ML/TF and ultimately share this information with reporting entities. Back Footnote 12 The drug dealer receiving the casino chips may attend the same casino at a later date, and redeem the chips for cash or a casino cheque. Casino chips can also be moved across borders, to be used as currency in illegal transactions or for money laundering activity. A large dollar value can be contained within a small number of chips casino slots chairs, which are less bulky than cash, and the chips can cross borders without declaration, since most jurisdictions do not consider them to be monetary value instruments. Back Footnote 11 To simplify the text throughout the rest of the document, "illicit cash" or "illicit funds" is used when FINTRAC or reporting entities suspected that the origin of the funds were criminal in nature. Back Analysis of reports submitted to FINTRAC by financial institutions and casinos gave FINTRAC reasonable grounds to suspect that the individual was involved in money laundering activity using two methods. TITO tickets may be used as currency in illegal transactions, offering the same advantages as casino chips, or may be used to directly launder the proceeds of crime. In both schemes, an individual inserts hundreds of dollars into a slot machine, engages in minimal play (or no play at all), and cashes out, receiving a TITO ticket. The ticket, which is usually valid for 30 days, can be used in illegal transactions, for example, the purchase of drugs. In this case, the drug dealer will redeem the ticket, or a number of tickets collected, for a casino cheque. The ticket can also be redeemed directly for a casino cheque. Footnote 19 Footnote 14 The conversion of foreign currency at casinos may be related to the need to use Canadian currency in slot machines. Back Footnote 15 "Vulnerabilities of Casinos and Gaming Sector." Financial Action Task Force & The Asia/Pacific Group on Money Laundering. March 2009. Back Automated currency exchange machines are available in certain casinos in Canada, and allow customers to exchange currency up to $3,000 canada online blackjack 4 you, which is the client identification threshold. It is therefore possible for a money launderer, or a group of money launderers, to refine and/or exchange currencies without interacting with casino staff. The automated currency exchange machine itself has no mechanism to identify, monitor and/or control this type of money laundering activity, and casinos must therefore rely on alternate surveillance and security measures to identify this technique. "Structuring" is a money laundering method that involves the division of cash or casino value instrument(s) to conduct a series of smaller value transactions in order to minimise suspicion and, in the case of cash, avoid threshold reporting requirements. Footnote 15 Structuring can also be combined with refining (structured refining) and currency exchanges (structured currency exchanges). When undertaken by a group of individuals, the method is also known as "smurfing." 47% Other offences, including theft, human trafficking, cigarette smuggling and corruption. The money laundering process is continuous, with new dirty money constantly being introduced into the financial system. Footnote 4 Internet payments systems (IPS) include various payment services offered online which include: 1) payment processing providers allowing merchants to authorize, settle and manage transactions from websites; 2) debit-account providers allowing users to accept electronic payments and make person-to-person funds transfers; as well as 3) digital precious metals operators offer a debit-account type IPS issuing digital currencies that are backed by precious metals. Back In addition, approximately 20% of the cases which included transactions in Canadian casinos involved organized crime, from street gangs, to outlaw motorcycle gangs, to traditional, transnational organized crime groups. While case disclosures involving organized crime groups related to a variety of predicate offences microgaming casinos 2014, the majority of case disclosures involving the presence of organized crime in Canadian casinos were associated with drug-related activity. Footnote 16 In instances where this type of activity was observed, the amount of the cash or casino value instrument that was passed was not known. However, most casinos generally prohibit this type of activity, and consider it suspicious. Given that in many cases, the subjects involved in this type of activity were repeat offenders, it is inferred that this activity is undertaken to avoid casino reporting, which as of September 2009 is required for disbursements over $10,000. Back Number of Case Disclosures Involving Transactions at Canadian Casinos First, it appeared that the individual deposited the proceeds of criminal activity to a bank account. The individual then layered the funds through casino transactions, making automated banking machine withdrawals at casinos and using the funds to purchase casino chips. Chips were later redeemed for casino cheques, which were deposited to the individual's bank account. Casinos in Canada play host to thousands of foreign tourists every year, and as such, most casinos offer currency exchange services. Such services are attractive to criminals, who may seek to convert currency obtained, for example, in cross-border drug transactions, in an effort to make the funds available for further use or to disguise their true source. The following table identifies the most common money laundering methods observed in case disclosures involving transactions at Canadian casinos. Many of the money laundering methods and techniques described in this report are known to casino regulators and operators. Criminals will continue to employ these methods and techniques as long as they are successful. FINTRAC determined that this individual was linked to the subject of a previous case related to drug importation/exportation, residential marijuana grow operations, the exportation of stolen vehicles and fraud. Canadian law enforcement was working with a foreign partner on the international dimensions of this investigation. Casinos, money services businesses (MSBs), and some trust companies or accounts-the latter service offered by trust companies or law firms-were also used to conduct financial transactions in cases disclosed by FINTRAC in 2008-2009, but to a lesser extent. Footnote 3 It was found that financial transactions were conducted at casinos in more than 100 disclosed cases. These transactions were mostly related to suspected drug offences and also to suspected fraud, organized crime activities and terrorist financing. Trust companies or accounts were involved in at least 80 cases that were suspected to be related to the same types of activities. 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