Investigation and Enforcement Activities

Modernization, transformation and integration

The 2021–2022 year saw the implementation of several important initiatives to drive efficiency. The Investigation and Enforcement Bureau (IEB) implemented the Management Inspection Process to ensure processes are incorporated into everyday operations, providing accountability, consistency and reliability.

Pre-screening applicants during the eligibility process is key to supporting the honesty and integrity of licensees, registrants and authorization holders. To support this process, the IEB implemented the Enhanced Cannabis Application Pre-Screening Interview process for Retail Operator and Retail Manager licences to allow for immediate flagging of any criminal associations. In 2021, enhanced Cannabis Application Pre-Screening Interviews identified 80 applicants as problematic or with areas of risk.

In the igaming sector, the IEB implemented Eligibility and Major Investigations pre-screening igaming CEO interview questions to identify any possible risks associated with the AGCO registration of igaming companies.

Anti–money laundering

Anti–money laundering (AML) continues to be a key focus for the IEB. In 2021–2022, the IEB implemented a new enhanced IEB AML investigative strategy that focused Ontario Provincial Police (OPP) resources to attend the casino floor any time they are called for a suspicious cash transaction when the patron is present at the casino. This allows the IEB members to engage and question the patron regarding the source of funds and determine investigative action.

Partnerships are key to the success of our AML programs. This year, the IEB developed and implemented a video to raise awareness of AML investigative analytic processes among stakeholders, including the OLG, the OPP, the AGCO and FINTRAC. These partnerships were further supported by introducing the IEB AML Coordination Model, where dedicated OPP, OLG and AGCO analysts worked closely to query and analyze their respective agency’s data sets to openly share and discuss information and identify individuals and activities that pose AML risks. The IEB also developed and implemented a new joint AML Investigative Process with the OPP

Provincial Asset Forfeiture Unit for identified High Priority Individuals that warrant an AML investigation that will utilize resources effectively.

A data-driven mindset is key to the IEB’s AML approach. An analytical program/dashboard tool has been developed and implemented to help identify and initiate investigations of individuals who pose risks of engaging in money laundering activities. The IEB has reduced a significant number of manual processes by automating the intake of all suspicious transaction reports (STRs) generated at Ontario gaming sites into the established IEB AML analytical program/dashboard tool. This allows the IEB to allocate resources to focus on high-risk gaming areas, and ground decisions and actions against high-priority individuals to determine if criminal investigations and/or regulatory recommendations are warranted.

To support data collection and drive these analytical insights in 2021–2022, the IEB launched a newly developed OPP Report Management System (RMS) STR investigative report and training video. The new report’s drop-down menus and entry fields walk the investigator through the investigation to ensure that nothing is omitted. This data is also trackable, assisting with future analysis of the information collected in the database and statistic collection. Implementing an enhanced IEB Harm Reduction Strategy and training video ensures consistency and that patrons attending casinos in violation of exclusion orders receive addiction assistance when required.

The IEB Intelligence Unit initiated a collaboration between the Biker Enforcement Unit and the RMS Unit to create a streamlined way to search, identify and compare those listed in the Outlaw Motorcycle Gaming databases to those within the AGCO’s regulatory database. This search resulted in over one thousand outlaw motorcycle gaming members’ names that can be compared to all regulated sectors.

Leadership and stewardship

The IEB Anti–Human Trafficking (AHT) Working Group collaborated with the OPP Anti–Human Trafficking Unit, Criminal Intelligence Service Ontario and municipal partners in order to proactively focus on AHT activities. The working group created a 2021 list of AHT police contacts from police jurisdictions across Ontario that house casinos and/or racetracks. The development of this initiative allowed investigators to quickly mobilize a multi-jurisdictional response to locate a wanted material HT witness from Quebec.

The IEB also provided support and subject matter expertise/follow-up to assist GTA municipal police counterparts on illegal gaming venues.

The Cannabis Intelligence Sharing Working Group involving the IEB/AGCO/ Provincial Joint Forces Cannabis Enforcement Team /OCS was implemented to share critical intelligence information, increase linkages to organized crime groups and enhance relationships. In addition, the Legal Cannabis Intelligence Working Group Due Diligence Investigators Network (DDIN) was implemented. The DDIN engaged cannabis regulators across Canada to share critical intelligence and information strategies from involved stakeholders and share linkages to organized crime connections and affiliations.