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In a significant decision for the gaming industry, the British Columbia Supreme Court has upheld the provincial lottery corporation’s right to restrict casino patrons who make large cash transactions, reinforcing anti-money laundering protections.
Patron Challenges BCLC Restrictions
The case centered on Ali Ghotaymi, who took the British Columbia Lottery Corporation (BCLC) to court after being placed on the organization’s “sourced cash conditions” list. The restrictions, implemented in 2015, target patrons making cash buy-ins of $10,000 or more at B.C. casinos.
Court documents revealed that Ghotaymi conducted 29 large cash transactions between February 2019 and July 2021, with eleven transactions totaling exactly $9,000 each. Casino surveillance also captured him making two $9,000 deposits at different casinos within a two-hour window in February 2020.
The Court’s Decision
B.C. Supreme Court Justice Matthew Kirchner dismissed Ghotaymi’s application, ruling that the BCLC’s conditions represent reasonable administrative controls rather than punitive measures. The justice emphasized that the restrictions do not prevent gambling but simply regulate the method of payment.
Ghotaymi, who works for Canada Post, contended that the restrictions damaged his reputation and could hinder future employment opportunities requiring security clearance. He maintained that his frequent $9,000 deposits represented legitimate winnings from previous casino visits, with net profits of $141,655 during the monitored period.
Because casinos cannot verify that cash buy-ins on one day necessarily originate from winnings on an earlier date, BCLC maintains that sourced cash conditions remain essential for large cash transactions. Patrons subject to these conditions must channel cash through their bank accounts, creating traceable records that leverage banks’ rigorous anti-money laundering protocols.
Historical Context: Dirty Money in B.C.
The ruling arrives against the backdrop of British Columbia’s well-documented casino money laundering scandal. The Cullen Commission’s 2022 investigation revealed that B.C. casinos processed approximately $1.2 billion in high-value cash transactions during 2014 alone.
The commission documented over 1,800 individual transactions exceeding $100,000 that year—averaging more than five per day. Investigators established clear connections between organized crime and these cash flows through provincial gaming facilities.
New Regulatory Framework Coming
Responding to these revelations, British Columbia passed the Gaming Control Act, scheduled to take effect in April. The legislation creates an independent gambling regulator and implements recommendations from both the Cullen Commission and Peter German’s 2018 Dirty Money report.
Justice Kirchner’s ruling specifically cited the public interest in combating money laundering, noting the dangerous nexus between criminal organizations and casino cash transactions.
Implications for Gaming Compliance
This precedent-setting decision strengthens regulators’ ability to implement sourcing requirements without facing successful legal challenges based on reputational harm claims. Gaming operators across Canada and beyond may look to this ruling when developing their own anti-money laundering protocols.
The case demonstrates that courts recognize the legitimate security concerns underlying cash transaction monitoring, even when individual patrons present plausible alternative explanations for their banking patterns.
