British Columbia Lottery Corporation

Lottery

Gambling products and services offered by the lottery line of business include the national draw products Lotto Max, Lotto 6/49 and Daily Grand, as well as BC specific lottery products BC49, the Extra, Keno, Scratch & Win tickets, and Sports Action. 

Lottery products are primarily sold through sales agreements with private sector retailers like pharmacies, gas stations, grocery stores and others.  

Lottery generated CDN$1.151 billion in revenue for the 2015/16 fiscal year.^[6]

Casino

The casino line of business provides traditional bricks and mortar casino gambling services.  These products include: slot machines; a full range of live table games including blackjack, baccarat, poker, craps, roulette, sic bo, and pia-gow; electronic table games; and, bingo.  Not all games are available at all facilities.  Offerings and availability are determined by local market demand.  BCLC operates 17 full service casinos, 19 community gaming centres (slot machines and bingo only), and 6 bingo halls.^[7] 

Casino generated CDN$1.814 billion in revenue for the 2015/16 fiscal year.^[8]

eGaming

BCLC's internet gambling services are offered through its PlayNow.com platform.  Lottery tickets for national and regional lottery games can be purchased on PlayNow.  The eCasino offers on-line slot and other casino games including poker.  Sports betting and bingo are also offered.   Due to a prohibition in the Criminal Code, sports betting is only offered on a pari-mutuel basis where bets must be placed on the outcomes of at least two events. Bets cannot be placed on the outcome of a single sporting event.  Additionally, the BC gaming regulator has interpreted the Criminal Code as prohibiting bets on races and fights.  The BC interpretation is unique as other provinces allow bets on both races and fights. Bets on the outcomes of single non-sporting events are permitted. A recent example saw BCLC take bets on the outcome of the 2016 United States presidential election.

eGaming generated CDN$135 million in revenue for the 2015/16 fiscal year.^[9]

GameSense

BCLC offers a responsible gaming program, known as GameSense, to assist players who experience difficulty in controlling the time and money they spend on gambling activities. The program offers information and advice both on-line and in hard copy at BC casinos as well as assistance through a toll free telephone number: 1-888-795-6111.   Most major casinos have GameSense advisers present and available to meet with players and members of the public to provide information on healthy gambling practices.^[10]

For those having serious problems controlling their behaviour BCLC offers a voluntary self exclusion program.^[11]  Players who sign up for this program are prohibited from going to any casino in BC for a set period of time.  Participants may choose 1, 2 and 3 year periods of exclusion.  While in the program, casino staff, and especially security and surveillance staff, with watch for the participant and require them to leave should they be found in or attempting to enter a casino.  Should a participant breach their commitment to stay away and enter a casino and go undetected, they are ineligible to win any casino prize during the exclusion period.

Participants in the voluntary self exclusion program are offered unlimited professional counselling services at no cost to the participant. 

A recent academic review of the program reported that participants found the program helpful and effective.^[12]

Problem Gambling

Individuals who experience difficulty controlling their gambling behaviour are often described as having a "gambling addiction".  Other sources make reference to "problem gamblers". The American Psychiatric Association formally refers to compulsive gambling behaviour not as addiction but rather "gambling disorder". (See: Diagnostic and Statistical Manual – 5). 

The government of the Province of British Columbia uses the term problem gaming and attempts to identify and track the scale of the issue through periodic prevalence surveys.  The most recent survey was conducted in 2014.^[13]

The survey methodology revolves around asking survey participants the nine questions on the Canadian Problem Gambling Index.   Based upon responses received to the nine questions, respondents are then classified into one of the following categories: non-gamblers, non-problem gamblers, low at risk problem gamblers, moderate at risk problem gamblers, high at risk problem gamblers. A total of 3,058 adult British Columbian's were surveyed by telephone or on-line.  The survey sample was not a random sample of all British Columbians.  The sample population was manipulated to deliver a minimum number of respondents from various regions of the Province.

The survey found that estimates of possible problem gambling prevalence had declined from the previous survey in 2007. The 2014 survey reports that 2.6% of respondents were at moderate risk of being problem gamblers and 0.7% of respondents were at high risk of being problem gamblers.  From these results the survey authors extrapolate the survey responses to the entire adult population of British Columbia and conclude that" [t]his represents an estimated 125,000 people considered to be problem gamblers". No individual was assessed in person by a qualified mental health professional and no respondent was diagnosed as having a gambling problem or disorder. The results are entirely dependent on responses provided to the nine questions by the survey respondents

The survey results are an estimate of the possible number of adults at risk of being problem gamblers in the province.  The estimate of possible problem gamblers from the prevalence studies are frequently mischaracterized in media^[14] and official reports as the actual number individuals in the province experiencing problem gambling behaviours rather than estimates of the possible number of individuals at risk of having or developing problem gambling behaviours. The Public Health Officer for British Columbia represented the 2007 prevalence survey results as finding that more than 100,000 people were in fact problem gamblers.  In his report Lower the Stakes: A Public Health Approach to Gambling in British Columbia, it states: "A combined total of 4.6 per cent (representing approximately 159,000 people in BC) were moderate-risk and problem gamblers" and, "[h]owever, the percentage of problem gamblers more than doubled, increasing from 0.4 to 0.9 per cent. Based on BC Stats population estimates for 2002 and 2007, this represents an increase in the approximate number of problem gamblers in BC from nearly 13,000 to more than 31,000 in only five years." [Emphasis added]^[15]

The survey concludes that the prevalence of potential problem gamblers in the province is very low.

For an evidence based discussion of addiction pathology and gambling disorder see Dr. Carl Hart at: https://www.youtube.com/watch?v=XtHrq6NCxG4

What is Money Laundering

Money laundering refers to the activities criminals use to make proceeds from their illicit activities appear to have originated from legitimate sources. Criminals engage in money laundering to protect themselves against prosecution and the forfeiture of their illicit proceeds.

Money laundering is typically composed of three phases: placement, layering and integration. The first phase, placement, occurs where illicitly acquired funds are put into the legitimate economy. This often occurs at a financial institution and is achieved by breaking large sums of cash into smaller amounts before making deposits into various bank accounts. Layering occurs where the money launderer moves the illegal funds through a serious of often complex transactions in an effort to disguise the funds or make the tracing of the origin of the funds as difficult as possible. The third and final phase, integration, involves using the funds in legitimate transactions such as the purchase of a business, real estate, investments or luxury items. With placement and integration money launderers will take steps to hide not only the illegal source of the funds but also their identity to prevent being linked to the illicit activities that resulted in the generation of the funds in the first place. Money launders may use various methods to target casinos. A common method is for a launderer to buy-in at a casino with cash from criminal activities, play with ony a small amount of money, and then cash-out requesting a cheque. The money launderer will then claim the funds from the casino are "winnings". Casinos may address this specific risk through a number of controls including: not offering cheques; only offering cheques where they can confirm the funds in question are in fact winnings; or, clearly branding cheques either the "return of buy-in funds" (in other words confirming the funds are not winnings) or "verified win"(only issued where the casino has tracked the player and can confirm the funds are in fact winnings).

Responses to Money Laundering

In Canada federal laws have been enacted in response to money laundering. Money laundering and the possession of the proceeds of crime are offences under the Criminal Code. Canada has legislation creating an anti-money laundering and countering terrorist financing regime (AML/CFT). That legislation is the Proceeds of Crime (Money Laundering) and Terrorist Financing Act or PCMLTFA.^[16] Some areas of the Canadian economy are seen as being more vulnerable to money laundering than others. Those sectors include banking, securities dealers, money services businesses, real estate, casinos and others. Companies in these sectors are deemed reporting entities under the PCMLTFA. The PCMLTFA also creates a financial intelligence unit (FIU). In Canada that organization is the Financial Transaction and Analysis Centre of Canada or FINTRAC. FINTRAC is responsible for the administration of Canada's AML/CTF regime.^[17]

Reporting entities, including casinos, are obligated to implement compliance programs to identify AML/CTF risks to their businesses and to put protections in place. A compliance program must include: a risk assessment; written policies and procedures; a training program; the appointment of a compliance officer; and an independent audit of the program once every two years. Reporting entities are obligated to report prescribed transactions to FINTRAC. Those transactions include any cash transaction of CDN $10,000 or more, suspicious transactions and attempted suspicious transactions of any dollar amount, and certain electronic funds transfers. Reporting entities have a number of other obligations under the PCMLTFA which include: ascertaining and confirming the identity of any person conducting a reportable transaction, keeping transaction records, and monitoring customer transaction activity. FINTRAC analyzes the reports sent to it by reporting entities for the purpose of detecting and deterring money laundering offences. Where its analysis identifies instances or suspected instances of money laundering or individuals involved in money laundering, FINTRAC will make a disclosure to the police agency of jurisdiction for the purposes of investigation and possible prosecution.

BCLC's Anti-money Laundering Program

BCLC has implemented an AML/CTF program designed to meet the requirements of the PCMLTFA. Its program incorporates all aspects of a compliance program required under the PCMLTFA. BCLC's compliance program is routinely audited by FINTRAC and the provincial gaming regulator to ensure it meets legislative requirements and works effectively.^[18]

BCLC has made a clear public commitment to meeting its compliance obligations.^[19]

A recent independent report noted robust AML/CTF compliance programs were present in Canadian casinos.^[20]