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At 9:30 PDT this morning (June 27, 2018) BC Attorney General David Eby QC convened a press conference to discuss the release of the much anticipated report by Peter German QC. Minister Eby was joined by German, a classic quadruple threat. Quite boring really. Lawyer (BC and Ont), former RCMP member of 31 years, Correctional Service Regional Deputy Commissioner, money laundering expert and textbook writer, PhD, and Queen’s Counsel. He does not, so far as we know, hold any Olympic medals, important medical patents or Eurovision victories.

Those who tuned in to the live stream, as I did, were given a summary rundown of the astonishing links between BC’s broken regulation of casinos, the absurd Vancouver real estate market, and the devastating opioid crisis.

The “Vancouver Model” of money laundering revealed in the report is a trailer of BC’s shame, although this was not the first we have heard of it. The BC AG had appeared in Ottawa a few months back to sound the alarm before the House of Commons Standing Committee on Finance.

But few had seen the actual report until today.

It is somewhat edited, we are told, by German himself to assure necessary privacy considerations, but it is now shared on the BC Government’s news portal (posted at the same time as the conference): https://news.gov.bc.ca/files/German_Gaming_Final_Report.pdf

The report was not searchable, however this version is: https://www.scribd.com/document/382738528/German-Gaming-Final-Report-OCR

Highlights of the Report and Press Conference

Recommendations of the report

I’m using the term “casinos” instead of “service provider”, but basically these are the Great Canadian Gaming Corporation, Gateway Casinos & Entertainment, and Paragon Gaming.

The report recommends:

Gaming in BC

R1 – Gaming Control Act (B.C.) be amended to facilitate the recommendations in the report.

R2 – GCA clearly delineate the roles and responsibilities of BCLC and the regulator, the Gaming Policy & Enforcement Branch.

Crown Corporation – BCLC

R3 – BCLC in concert with casinos and regulator, annually review the source of funds declarations (to see if adjustments are needed).

R4 T- BCLC remind casinos not to accept cash if they are not satisfied with a source of funds declaration.

Federal Reporting

R5 – make casinos responsible for completing reports to FinTRAC, including STRs (suspicious transaction reports).

R6 – discuss with FinTRAC how to get casinos to directly report to them, or at least how to get BCLC to do this.

R7 – BCLC provide Corporate STRs if its files contain relevant information not contained within an STR from a casino.

R8 – casinos develop the necessary capacity to assess risk and perform due diligence on suspicious transactions.

R9 – casinos copy STRs to BCLC, the regulator and a new designated policing unit (DPU), and the RCMP.

R10 – the regulator/DPU have access to iTRAK in its offices.

Provincial Reporting

R11 – eliminate existing “suspicious currency transaction” and “unusual financial transaction” reporting.

R12 – develop a Transaction Analysis Team to review all suspicious transaction reports.

R13 – weekly meetings for the Transaction Analysis Team to review all suspicious transaction reports and develop strategies to deal with each.

Joint Integrated Gaming Investigation Team (JIGIT)

R14 – provide JIGIT with support for its investigative mandates.

R15 – consider transitioning JIGIT to a permanent, fenced funding model within the RCMP’s provincial budget.

BCLC Goes Undercover

R16 – stop BCLC from doing undercover operations, except in conjunction with the regulator and, or the police.

Software Debacle

R17 – stop BCLC from spending money on the SAS AML software system.

Very Important Patrons

R18 – BCLC ensure that VIP hosts do not handle cash or chips.

R19 – those working in VIP rooms get an independent avenue to report incidents of inappropriate conduct by patrons.

Cash Alternatives and Cash Limits

R20 – make cash alternatives the responsibility of the casinos, subject to their compliance with overarching standards.

R21 – don’t impose cash limits on buy-ins.

R22 – eliminate patron gaming fund accounts once responsibility for cash alternatives is transitioned to casinos.

Chips Go Walking

R23 – BCLC implement a chip tracking system for casinos.

Standards-Based Industry

R24 – transition casino industry to a standards-based model.

R25 – develop standards-based model via cross-sector of industry and government, building on Ontario Standards.

R26 – make the CEO / Registrar of the regulator be the keeper of the standards.

A New Regulator

R27 – transition to an independent regulator in the form of a Service Delivery Crown Corporation, with a Board of Directors and a CEO / Registrar

R28 – have the regulator’s board be a governance board and not be responsible for appeals from decisions of the Registrar.

R29 – regulatory investigators to be Special Provincial Constables.

R30 – make anti-money laundering and mandatory training a responsibility of the Regulator (re front line gaming personnel, VIP hosts).

R31 – make Regulator the regulator of BCLC and make BCLC Board, officers and employees be subject to registration.

R32 – have Regulator provide a 24/7 presence in the major Lower Mainland casinos, until a designated policing unit is in place.

R33 – appeals from Registrar decisions to be sent to an administrative tribunal constituted for this purpose, or already in existence.

R34 – fund Regulator from gaming revenue still.

R35 – ensure Regulator has dedicated in-house counsel.

R36 – hire Regulator investigators to meet core competencies.

Gaming Police

R37 – create Designated Policing Unit to specialize in criminal and regulatory investigations in legal gaming industry, with an emphasis on Lower Mainland casinos.

R38 – make DPU an integral part of the Regulator.

R39 – DPU not responsible for investigating illegal gaming outside casinos.

R40 – provide DPU with an Intelligence Unit.

R41 – study OPP Casino Bureau and the Nevada GCB Enforcement Division to determine an appropriate role for the DPU.

R42 – make anti-money laundering a specific responsibility of the DPU.

R43 – fund DPU from gaming revenue.

R44 – ensure Provincial prosecution service has prosecution counsel familiar with gaming law.

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Vulnerable Sectors

R45 – undertake research into allegations of organized crime penetration of the real estate industry.

R46 – consider a licencing and recording regime for money service businesses, similar to the Metal Dealers Recycling Act.

R47 – consider researching the vulnerability of the luxury car sector and the horse racing sector to organized crime.

R48 – continue to encourage the federal government to amend the POCMLTFA to broaden the entities subject to reporting, specifically luxury goods of interest to organized crime.

The interim recommendations

The report includes letters German earlier sent to the AG Eby in late November 2017 and in March 2018 with interim recommendations:

Require Gaming Service Providers to declare source of funds for cash deposits over $10,000, and include ID, financial institution and account of source money.
Put a Gaming Policy and Enforcement Branch investigator on shift 24/7 at high volume casinos.
Appear before the House of Commons Standing Committee on Finance

Security footage: bags and stacks of dirty money

Some of this stuff looks like a poorly shot Guy Ritchie homage. B

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