FINTRAC may be informed of the suspected predicate offence through information that is volunteered by law enforcement or that is included in a suspicious transaction report. In instances where FINTRAC was able to link suspected money laundering activity to a predicate criminal offence, fraud and drug-related activity were the most frequently observed suspected offences. As in previous years, for the cases where fraud was suspected, investment/securities and telemarketing fraud were the most observed. For cases where drug-related activity was suspected, the majority of cases involved the trafficking of cocaine and/or marijuana.
Given the nature of its business, the casino sector is an important stakeholder in the national effort to deter, detect and prevent money laundering. As FINTRAC's Director, it is my hope that this special report will improve collaboration in support of better financial intelligence for our law enforcement and national security agencies. FINTRAC depends on receiving reports from many different sectors, such as casinos and banks, to produce this financial intelligence. The previous Typologies and Trends report produced for banks provided assistance to that sector, and I believe this special report will also go a long way in helping the casino sector with its compliance regimes.
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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.
What is Money Laundering? - KYCMap
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.
Money Laundering Typologies and Trends in Canadian …
In an effort to provide additional insight, the following are actual cases that were disclosed to law enforcement in 2008-2009. The cases have been sanitized; all identifying information has been removed, and they were chosen for inclusion as they involved transactions incorporating many of the money laundering methods previously described. The "red flags" associated with each case assisted FINTRAC in reaching the threshold for reasonable grounds to suspect that the information would be relevant to a money laundering investigation, and thus disclose the case.
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The description of the use of credit cards in casinos as part of money laundering activity highlights another feature common to many FINTRAC case disclosures involving Canadian casinos. Often, the overall money laundering process includes transactions in more than one financial sector, and transactions at casinos represent only a part of the overall laundering scheme. Although casinos may not be privy to the transactions occurring through other sectors, knowledge of how certain casino transactions may be part of a money laundering scheme, or how certain casino transactions may be indicative of money laundering activity, will help casino staff identify suspicious transactions that should be reported to FINTRAC.
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One reason for the importance of front money accounts in FINTRAC case disclosures is that they offer similar services to those offered by more traditional financial institutions, at least with regard to the storage of funds. Money launderers and other criminals may believe that, despite these similarities, front money accounts are subject to less scrutiny than accounts at financial institutions used for the same purposes. Front money accounts can also be used in conjunction with many of the money laundering methods previously described.