Money Laundering in British Columbia Casinos
By Garry Smith
How to cite:
Smith G. (2019). Money Laundering in British Columbia Casinos. Critical Gambling Studies. https://doi.org/10.29173/cgs12
The Issue
For the past
decade Vancouver casinos have been a haven for loan sharks and money launderers
seeking to camouflage and exploit the proceeds of drug trafficking. These
activities have made Vancouver casinos a cesspool of financial crime. High
rolling Chinese organized crime members were recruited in Macau casinos to gamble
in Vancouver. Millions of dollars from illegal drug sales in China were first deposited
into illegal Canadian banks, then later retrieved by gang members to gamble in lower
mainland British Columbia casinos. Preferring to play baccarat in exclusive VIP
rooms with a maximum wager of $100,000; win or lose, after cashing out, ‘dirty’
drug money is converted into ‘deodorized’ untraceable casino chips. An
estimated $2
billion in ill-gotten gains was washed through Vancouver gambling
outlets (much of it in Richmond’s River Rock casino). The Vancouver
Sun investigative reporter who uncovered the scandal, estimated that
the top ten Chinese VIPs accounted for close to 50% of all the casino laundered
proceeds of crime.
The money
laundering scheme was blatant to the extent that Chinese gamblers entered the
casino with duffel bags filled with $20 bills (the preferred currency of drug
dealers) and in some instances accidently spilled cash on the casino floor in
plain sight of casino staff and patrons. Even so, casino operators allowed the suspicious
VIPs to buy chips without reporting the inordinately high buy-ins to the
Financial Transactions and Reports Analysis Centre of Canada (Fin-TRAC), the
federal agency that requires a report on casino monetary exchanges exceeding
$10,000.
How and Why it Happened
Key
regulatory agencies for British Columbia casinos include 1) the British
Columbia Lottery Corporation (BCLC), a crown agency which has the dichotomous
responsibilities of growing the business of gambling in the province while at
the same time ensuring that gambling operations are fair and tightly
controlled; 2) The Criminal Code of Canada, the federal authority under which
provinces regulate approved legal gambling formats. The enforcement of Criminal
Code violations rests with various law enforcement agencies, including city
police, the RCMP and provincial government gambling regulators; 3) casino
owners operate under provincial license which spells out stringent rules for
mitigating on-site criminal activity. Casino oversight
was egregiously flawed at the BCLC, casino management and elected
official levels. Earlier in the decade the BC government received the highest
monetary penalty ever from Fin-TRAC for non-compliance with its money
laundering prevention procedures. BCLC regulators and casino management ignored
RCMP and local police intelligence concerning the waves of Chinese high rollers
frequenting Vancouver casinos and gambling with funds of shadowy origins. Instead
of tightening financial crime surveillance in BC gambling venues, the
government raised its high roller betting limits from $5,000 to $100,000 a
play. A decision that was justified by
claiming that casino revenue maximization is in the public interest.
The Aftermath
A changeover
in provincial governments resulted in the commissioning of a report on
gambling-related financial crime. Former RCMP senior executive Peter German
produced a 247-page document entitled “Dirty
Money: An Independent Review of Money Laundering in Lower Mainland Casinos.”
The scandal was said to be the result of a total system failure, yet no
criminal charges were laid, politicians ousted, or casino licenses suspended.
The report resulted only in some recommendations on how casino money laundering
can be better regulated. Public reaction
to the report was ambivalent, there was a pervasive feeling that culpable
actors should be fired and/or indicted and that casino licences should either be
suspended or withdrawn. The current Attorney General is pondering
a further investigation yet moving at a glacial pace and stating
that an inquiry may be too expensive to undertake. [1]
Another concern is that by allowing provinces to conduct and manage their own
gambling operations, federal government detachment has contributed to improprieties
such as the lack of effective casino oversight in BC.
Lessons to be Learned
Gambling is
known to be a volatile activity that can have a detrimental effect on both
individuals and communities if not tightly regulated. The combination of
decriminalized and expanded gambling under Canadian provincial government
monopolies is ripe for exploitation and corruption. Nearly a half century ago,
gambling regulation authority Jerome Skolnick made the following observations
(which would seem to be truisms concerning the ethically gray world of
commercial gambling and its regulation) in his seminal book House of Cards: The Legalization and Control
of Legal Gambling.
·
When
the purpose of legalizing gambling is to raise revenue, a state will face the
dilemma of regulating an industry, while at the same time, encouraging it to
prosper. This conflict of interest is at the heart of the BC money laundering
scandal; to wit, the BC government and casinos have a perverse incentive to
look the other way when money laundering occurs. If they curb the activity
sizable revenues will be lost.
·
The
larger the economic interest of the state in gambling, the greater is the
outside pressure to erode mechanisms of control. In this case, casino industry
capture of government regulators paved the way for rampant money laundering.
·
Classic
issues of gambling regulatory law enforcement include the sources of stringency
and leniency in the interpretation of rules. In this case, because the BCLC and
the casinos were in effect partners, regulators exercised willful blindness in
their oversight to the benefit of each party and the detriment of the public
good.
[1]
Since the initial writing of this blog entry, the BC government has announced
a wide-ranging investigation into money laundering in the province.
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