Administrative financial penalty on Saskatchewan Indian Gaming Authority

[2025-09-12]

Saskatchewan Indian Gaming Authority, additionally working as SIGA, was imposed an administrative financial penalty of $1,175,000 on August 28, 2025, for committing 3 violations. The violations had been discovered through the course of a compliance examination.

Nature of violation

Violation #1

Failure to submit suspicious transaction stories the place there have been affordable grounds to suspect that transactions had been associated to a cash laundering or terrorist exercise financing offence – Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act), part 7.

FINTRAC decided that SIGA didn’t submit 4 suspicious transaction stories the place there have been affordable grounds to suspect that a number of transactions or tried transactions had been associated to the fee or tried fee of a cash laundering or terrorist exercise financing offence. FINTRAC concluded that SIGA was conscious of ample related data, coupled with the presence of a number of cash laundering indicators of suspicious exercise needed, to fulfill the affordable grounds to suspect threshold for reporting suspicious transactions. These indicators included: shopper displays data of reporting thresholds; the transactional exercise (degree or quantity) is inconsistent with the shopper’s obvious monetary standing, their normal sample of actions or occupational data; transactions contain individuals recognized by the media, legislation enforcement and/or intelligence companies as being linked to felony actions; and enormous and/or speedy motion of funds not commensurate with the shopper’s monetary profile. These indicators exhibit that SIGA had affordable grounds to suspect that the transactions performed by the patrons had been according to these associated to the fee or tried fee of a cash laundering or terrorist financing offence.

Violation #1 is assessed by the laws as a Very Serious violation. The imposed penalty takes into consideration the factors in part 73.11 of the Act and part 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #2

Failure to report suspicious transactions with the prescribed data – part 7 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and subsection 9(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious
Transaction Reporting Regulations.

FINTRAC decided that, in 3 cases, SIGA didn’t embody any cash laundering or terrorist financing indicators within the “Details of suspicion” part of the suspicious transactions stories that it submitted. Failing to submit stories in accordance with the rules ready by FINTRAC might stop FINTRAC from effectively analyzing data and will even render the data unusable for evaluation.

Violation #2 is assessed by the laws as a Serious violation. The imposed penalty takes into consideration the factors in part 73.11 of the Act and part 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #3

Failure to develop and apply written compliance insurance policies and procedures which can be saved updated, and, within the case of an entity, are authorised by a senior officer – subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 156(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

FINTRAC decided that SIGA had insufficient insurance policies and procedures for the continued monitoring of high-risk and excessive high-risk patrons. SIGA didn’t correctly assess the danger for all of its patrons. In 41 out of 100 cases reviewed, SIGA listed its patrons’ threat degree as “none”. In accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and related Regulations, a on line casino is required to threat assess a patron when it enters right into a enterprise relationship. When this enterprise relationship is established, ongoing monitoring necessities are triggered, the place a on line casino should evaluate all data obtained in regards to the patron with whom it has a enterprise relationship, together with the unique threat evaluation. Since SIGA didn’t have an unique threat evaluation (“none”), it didn’t conduct its ongoing monitoring and its enterprise relationship necessities.

Violation #3 is assessed by the laws as a Serious violation. The imposed penalty takes into consideration the factors in part 73.11 of the Act and part 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

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