The Saskatchewan Indian Gaming Authority (SIGA) is the latest Canadian gaming entity to challenge the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in federal court after being fined.
FINTRAC fined the non-profit First Nations casino operator $1.175 million on Aug. 28, stating that SIGA had committed three compliance and/or reporting violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
FINTRAC determined that SIGA failed to file four separate suspicious transaction reports (STRs) despite reasonable grounds to do so, did not include money laundering or terrorist financing indicators in STRs that it did submit and failed to “properly assess the risk for all of its patrons.” The financial watchdog claimed that SIGA ignored multiple indicators of suspicious activity that met the threshold for reasonable grounds to report suspicious transactions.
SIGA’s appeal, filed on Sept. 26 and obtained by Canadian Gaming Business, names the Attorney General of Canada as the primary respondent and FINTRAC as a co-respondent.
SIGA alleged that FINTRAC Director Sarah Paquet committed “palpable and overriding errors” in her judgment and contradicted the findings of her own agency.
Exam’s focus was unprecedented
SIGA runs seven First Nations casinos in Saskatchewan and also operates the province’s only regulated and authorized online gaming website, PlayNow.com. In accordance with Saskatchewan’s gaming model, all of SIGA’s net revenue is reinvested into First Nations, local communities and the province’s coffers.
It noted that it has been the subject of eight FINTRAC examinations since 2007, including the most recent one in September 2024 that resulted in the million-dollar fine, and had never previously been issued a notice of violation or financial penalty until now.
The First Nations operator stated in its appeal that the 2024 exam focused on SIGA’s policies and procedures related to STRs, high-risk patrons and activities and transaction monitoring, things that SIGA asserted had never been the focus of any of the past FINTRAC exams.
After FINTRAC shared its findings with SIGA verbally on Sept. 27, 2024, SIGA said it provided a written list of actions it had taken in response on Oct. 3, 2024. FINTRAC subsequently cited SIGA for three violations.
Director overruled findings
SIGA disputed FINTRAC’s findings in May 2025. Among other complaints, the appeal claimed that Paquet determined that SIGA had filed prior STRs with respect to some of the alleged violations, even though FINTRAC had found this was not the case. SIGA also argued that Paquet did not reduce the financial penalties despite acknowledging that it is FINTRAC’s policy to do so when the entity being assessed has never been penalized before.
In addition, SIGA claimed that despite FINTRAC finding that 39 of 100 reviewed STRs contained no money laundering or terrorist financing indicators, Paquet overruled that conclusion and determined that 36 of those 39 STRs did in fact contain money laundering indicators.
“The director committed a palpable and overriding error in concluding that the appellant committed each of the three violations and in assessing the applicable penalties with respect to each violation,” wrote SIGA. The organization added that Paquet failed to apply or misapplied correct legal tests, took into account irrelevant considerations in her findings, committed errors in law and misconstrued SIGA’s reporting and FINTRAC’s own findings.
SIGA asked for the appeal to be allowed, for FINTRAC’s decision to be quashed and for all financial penalties to be vacated or at least reduced.
Following in footsteps
SIGA’s appeal in federal court follows similar challenges in recent weeks from the temporary, non-profit Canadian National Exhibition (CNE) casino in Toronto, which was fined around $200,000 for allegedly failing to conduct either an adequate risk assessment procedure or a compliance review, and the British Columbia Lottery Corporation (BCLC), which was fined $1 million for multiple alleged AML violations.
In their respective federal court appeals, CNE Casino and BCLC also claimed FINTRAC erred and misconstrued in its decisions. CNE Casino denied committing any PCMLTFA violation and pointed to a lack of criminal activity, while BCLC claimed it was “ambushed” by the financial watchdog.
