04-02-2021

Casino Money Laundering Vancouver



Rich Coleman, pictured in 2014. BC Government photo

Former Minister of Public Safety and Solicitor General Rich Coleman heard directly from a lead casino investigator in December 2010 how VIP patrons were routinely gambling with larger and larger bundles of suspected illicit drug proceeds, the Commission of Inquiry into Money Laundering in B.C. was told Thursday.

The Cullen Commission of Enquiry into money laundering in British Columbia has illuminated just how frustrating it is for investigators trying to do their jobs and to do the right thing. It’s a clear example of when the investigative will meets the “bureaucratic won’t.”. The inquiry, created to determine whether corruption allowed money laundering to take root in B.C. Casinos, has heard that transactions of $100,000 were common in Vancouver-area casinos a decade ago. Moneylender and illegal casino operator Jin was the initial target of Operation E-Pirate. He was suspected of money laundering because of his involvement in nocturnal deliveries of large amounts of.

Larry Vander Graaf, former Gaming Policy and Enforcement Branch (GPEB) executive director of investigations, told Commissioner Austin Cullen how following the 2010 Winter Olympics in Vancouver, large cash buy-ins were increasing exponentially.

“Money laundering was on the move,” in B.C. gaming facilities, said Vander Graaf.

As such, Coleman met briefly with Vander Graaf at GPEB headquarters in Burnaby, alongside Deputy Minister Lori Wanamaker.

“Mr. Coleman opened the conversation,” said Vander Graaf. “He said, ‘What about this money laundering?’ And I said they're bringing it in in $10,000 bundles. He says, ‘I know lots of people with $10,000 in their pocket.’ I said, ‘If it's in $20 bills with elastic bands on both ends, you better check your friend zone,’” added Vander Graaf to commission counsel Alison Latimer.

“I explained to [Coleman] about the horrendous problem we were having in the casinos with the $20 bills, that $20 bills are a problem to drug traffickers. And it's a [$6 billion to $7 billion] industry,” said Vander Graaf.

“Money Laundering was resurfacing as a problem in the casinos,” he added. “It was an integrity issue to gaming. I felt that we had to do something about it. I felt that we should,” said Vander Graaf, who noted Coleman was receptive to his assertions.

“The only thing that Miss Wanamaker said was ‘Rich, we have to do something about this.’ That was the extent of that conversation,” said Vander Graaf.

Vander Graaf said he did not follow up with Coleman’s office following the meeting; however, he said his superiors, who would be in direct contact with the ministry, were well aware of the concerns from GPEB investigators.

However, by November 2011, one casino patron brought in $1.38 million worth of $20 bills across 13 transactions, the commission heard.

Furthermore, RCMP E-Division was aware of the issue at the time, as Latimer raised a 2010 letter from Vander Graaf’s superior Derek Dickson, GPEB director of investigations, to the BC RCMP Integrated Proceeds of Crime (IPOC) unit that notes meetings between the two agencies — which both report to Coleman.

“Mr. Dickson sets out that he and Mr. Schalk [GPEB senior director of investigations] met with the officer-in-charge of the RCMP integrated proceeds of crime unit. And they are well aware of this issue and seriously concerned that the casinos are being used as a method to launder large sums of money for organized crime groups. And they say they are of the opinion that this is without doubt, large-scale money laundering.”

At the time, Vander Graaf had suggested to superiors limiting buy-ins with $20 bills to $10,000.

“That was not a long-term permanent fix. That was a fix that could have been instituted immediately.

“It may have created some smurfing, you know, under a limit, but it would have eliminated the problem fairly quickly,” said Vander Graaf.

The suggestion was never accepted and Vander Graaf said he later suggested a $20,000 limit that was also rejected.

“You're raising the threshold just to try to make the suggestion more palatable?” asked Latimer.

“Exactly,” said Vander Graaf.

“We were constantly going to [IPOC] and dealing with them and trying to get them to instigate action in relation to the money laundering issue,” he said.

But whereas Vander Graaf had begun communicating with IPOC, the unit was subsequently disbanded in 2013, despite being “the logical first response unit for allegations of money laundering,” according to the 2018 report Dirty Money by former RCMP assistant commissioner Peter German. Prior to IPOC being disbanded, the Integrated Illegal Gaming Enforcement Team (IIGET) had received the same fate in 2009 on Coleman’s watch.

The commission has heard testimony from a number of current and former government employees from the three major entities tasked to regulate gaming and enforce laws: GPEB, the RCMP and the B.C. Lottery Corporation.

GPEB is the province’s equivalent of the Nevada Gaming Commission, in that it is mandated to set gambling rules and enforce them. BCLC is the government body that licenses casinos and other gaming venues. BCLC also has a mandate to manage and promote gaming, and issues net gaming revenue to the provincial government.

Commission counsel has focused questioning on how government balanced gambling regulations and revenue.

Vander Graaf, not unlike other casino investigators who have testified, asserted the B.C. government was in a conflict of interest. He also spoke to how deregistering casinos was never in the regulatory toolbox, at least up until the time he was fired in December 2014 for what he believes to be his honest criticisms toward his own agency.

Vander Graaf explained that neither GPEB nor BCLC investigators, whose mandates appeared to overlap, had perceived to have power to stop large cash buy-ins on casino floors. Rather, the job was to observe and report.

“We knew, and I always knew, that we could never investigate money laundering and proceeds of crime at GPEB and that neither could BCLC. And we all knew that they're too complicated. You need the full-blown policing agency to take a run at them,” he said.

Around 2013, police efforts to address casino-related crime appeared to turn toward the RCMP Combined Forces Special Enforcement Unit, which would later open an investigation called E-Pirate, focusing on loan sharks working with local underground banks connected to Asia that dispersed local drug money to wealthy Chinese nationals who would skirt capital controls in the People’s Republic of China.

Vander Graaf stated how for several years the BCLC took the position that because a gambler lost money it meant that money laundering was not occurring. Documents presented by Latimer showed Vander Graaf raising concerns about such misguided beliefs, as he noted the loaned (and lost) drug money would have to be repaid in some form.

“The loan sharks would have loved getting something other than the $20 bills back,” he explained.

And so, regardless of any police presence, Vander Graaf said GPEB and BCLC failed to properly regulate casinos that were also “blatantly” violating federal cash transaction laws, including not reporting any cash buy-in under $50,000 as suspicious for upwards of four years.

Despite his efforts to tip off police, “that didn't absolve us of the role that we had to play and we didn't do it,” said Vander Graaf.

Laundering

There are several key methods that criminals deploy when money laundering. Many groups rely on breaking up the deposits into small tranches to avoid flagging in a practice known as structuring. Others simply buy chips with cash, spend some time on the casino floor and attempt to cash them out as winnings. There are many methods that involve the use of shell companies to conceal transactions, bank accounts and individuals involved. It is an incredibly complex area of finance and one that the authorities are fighting tirelessly to stamp out in all forms.

What Makes Casinos the Perfect Target?

Casino gambling is a brilliant way to make money disappear, and reappear in separate bank accounts. Obviously, the casino industry takes measures to make this difficult which we will explain in more detail down the page. The casino does not necessarily need to be complicit in the money laundering activities for criminals to be successful, but many have known to be in the past. With so many underground markets operating throughout Asia, Europe and America – criminals have plenty of casinos and sports betting operators they can exploit to launder their dirty cash.

Without the compliance of the regulated casino industry, this is an uphill battle that the authorities cannot fight alone. There are many motivated, and well-funded criminal gangs that are persistent in their efforts to use casinos to launder money. Within the casinos, themselves exist many vulnerabilities that can be easily exploited. The staff in casinos represent one of the biggest risk factors for money laundering, as they are often low-paid administrative staff that can be easily bribed or threatened to assist the criminals laundering their money.

But what makes the casino money laundering so appealing rather than off-shore shell companies or other such methods.

The three biggest reasons for money laundering at casinos are:

  • Casinos and sports betting operators have enormous cash flows that make it easy to bets intended for money laundering within the sea of transactions flowing in and out.
  • It doesn’t matter who you are, whether you’ve been convicted of financial crimes or where your money comes from. The majority of casinos around the world are happy to accept wagers from anyone with hard cash to gamble.
  • High-rollers are a major source of profit for many casinos – in order to maintain a strong a favorable relationship with the client, staff may ignore or turn a blind eye to any suspicious transaction.

As you can imagine from the above statements, revenue and profit are huge motivating factors for the casinos. It is difficult to deny that casinos are powerless to stop this activity, and certainly more needs to be done from industry regulators to enforce systematic checks on customers that set-off red flags with suspicious depositing activity.

Industry regulators certainly have a part to play, by scrutinizing large casino companies around the world they regularly audit and analyze financial statements looking for irregularities. The biggest operators make enough money from legal transactions, and it tends to be smaller casinos in less stringent jurisdictions that are complicit with money launderers. In Asia, there has been a long-term problem with this illegal activity – and a thriving underground gambling industry.

Things are a little different online, especially if you are gambling in the UK or another strictly regulated market. If you are worried about what might be going on at your favorite casino site, have a look at our guide to casino safety to see what reputable sites are doing to keep everything above board.

Fighting Against Money Laundering with Regulation

Within tightly regulated industries such as Europe and North America casino money laundering is a very low threat to operations. The regulators in these territories are very diligent, using a mixture of law enforcement integrations, technology, and correct procedures to mitigate the problems. Communities in Europe and North America are more resistant to the risks associated with exposing themselves to organized crime and are more active in their resistance to money launderers.

However, the Asian gambling industry is worth over $180bn annually. Before the market became such an enormous part of the local economy, a strong and thriving underground gambling scene was firmly established. Even now that big corporate casino interests have a firm hold on the market, the dark underbelly still remains.

Vancouver Casino Money Laundering Video

Certain casinos within Asia are notorious for being connected to the criminal underworld – on a much larger scale than any European equivalent. It has been proven in the past that the Yakuza has a strong grip over many gambling operators in Japan, and in South-East Asia there have been several high-profile match-fixing and money laundering busts in the past decade.

Vancouver Casino Money Laundering

The tide is turning though. Many of these casinos have begun enforcing identity checks on their new customers. More importantly, the range of payment options that was previously available has been refined to a select few, in this scenario payments are much more easily traced. The ability to use different accounts for deposits and withdrawals has enabled casino money laundering in the past, ending this practice will do a great deal for squashing the remnants of money laundering in this industry.

Is the Game Up for Money Launderers?

Casino Money Laundering Vancouver Canada

Obstructing the use of casinos as a vehicle for money laundering is a constant battle between law enforcement, criminals and casino operators. In the UK, customer check procedures are continuously improving, and in its current state, the system is highly impenetrable. The same rings true for much of Europe and North America. However, the lackluster approach to financial scrutiny in certain jurisdictions continues to allow the practice of money laundering to sneak under the radar. The amount of money involved is truly staggering, with that comes powerful and illicitly motivated groups who are determined for their business to go uninterrupted. The battle rages on between criminals and the authorities who are often left chasing shadows.

Money Laundering Through Casinos

You can find out more info about how casinos stay safe from crime and how internet gambling is regulated in this section of our guide to real money casino gambling.