Advocacy is important work for the Canadian Gaming Association (CGA), as the CGA’s efforts have helped to shape public policy and expand access to gaming while pushing back against misinformation that too often appears in the media. The CGA’s objective is to champion the advancement of the gaming industry to support member, employee, and marketplace needs.
We celebrated the first anniversary of Ontario’s iGaming market launch with a specially curated program on April 4th with over 175 people in attendance.
The CGA held two Member Town Halls as well as member-focused events at ICE, the Canadian Gaming Summit and G2E, plus Canadian industry meet-ups at SBC North America and SBC Barcelona.
The first SBC-run Summit in Toronto saw record attendance and member participation.
We increased participation in the Association via committees, project & sector working groups, events, and networking opportunities to address issues such as AML, Responsible Gaming, & Government Advocacy.
And we regularly brought members together to discuss issues of common cause (AGCO Advertising Standards, for example) and outline the industry’s response.
The CGA submitted responses to both iGaming Ontario and the AGCO to provide the industry’s perspective on several important issues:
- Advertising Standards and related guidance.
- Mandatory RG ads and centralized self-exclusion.
- Technical Requirement Changes to Casino-Related Eligibility.
Specific to the Parliamentary Review of Canada’s PCMLFT Act, the CGA provided a 13-page submission in August 2023: Consultation on Strengthening Canada's AML & ATF Regime.
The Association also continued to be a strong voice for our industry as CGA has regularly commented in the media on several issues related to sports betting advertising and Ontario’s overall iGaming market.
The first SBC-run Summit was held in Toronto in June 2023 and the CGA helped to build the speaker and program roster to enhance member education and engagement.
We will continue to work with SBC to build the education program for the 2024 Summit as we understand the need to showcase Canadian organizations and talent.
Late in 2023, we launched the CGA’s Action Plan to Promote Responsible Play - as an industry, we have a tremendous opportunity – and responsibility – to come together to advance the evolution of a regulated, responsible, and sustainable Canadian gambling industry. The strategy was developed following a consultation process that included member surveys, focus groups and lengthy discussions by the CGA Board.
Looking ahead to 2024, we want to build out and implement our Action Plan:
- Completion of industry RG Guiding Principles.
- Develop and implement a National Advertising Code.
- Explore enhanced public education efforts with industry stakeholders and partners.
2004 Advocacy Priorities
The CGA outlined its 2024 advocacy priorities at its AGM in early December 2023:
- Actively participate in the Parliamentary Review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTF Act) to ensure Canada’s AML laws and regulations better reflect the evolution of Canada’s gaming industry.
- Engage the Canadian Senate on Bills S-268 and S-269 to work with the Senate to ensure that Canada’s gaming industry is actively consulted and doesn’t face unnecessary regulation.
- Actively work with the Government of Alberta and AGLC as they explore enhancements of Alberta’s gaming model.
- Continue to be a voice for the industry for the reduction of needless red tape and duplication, controlling costs related to compliance.
- Promote the benefits of the gaming industry on the Canadian economy.
Previous Advocacy Work
The CGA invests in a variety of research to ensure that current and factual information is available and easily sharable. Here you will find fact sheets, reports, proprietary studies, and infographics covering a wide range of topics from the economic impact of the Canadian gaming industry to the attitudes of leaders who have opened casinos in their communities.
The CGA acts as a resource to the industry with its advocacy efforts. Policy positions are identified based on discussions with stakeholders to identify issues that would benefit multiple provinces and/or lottery corporations. Single-event sports wagering /Bill C-218 is an example of how the CGA advocated with the federal government on legislative issues affecting the industry. Other policy positions that the CGA has been involved with include:
- Resolving a potentially restrictive proposal from the Television Bureau of Canada relating to gaming advertising guidelines
- Defeating a bill in Parliament that would have restricted gaming devices to facilities of a certain (and larger) size
- Meeting with senior federal Department of Finance officials and making written submissions regarding proposed amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act as it relates to casinos and testifying before a Senate Committee on the subject
Single-Event Sports Wagering
Brief History of Bills C-290 and C-221
Bill C-290, An Act to Amend the Criminal Code – Sports Betting, was introduced into the House of Commons in September 2011 by the Honourable Joe Comartin, M.P. for Windsor Tecumseh, and initially passed the House of Commons with all-party support. It was studied and debated in the Senate over a three-year period but was never voted on, and it died on the order paper when Parliament was dissolved for the general election in 2015.
Bill C-221, The Safe & Regulated Sports Wagering Act, was defeated by a vote of 156-133 at second reading in the House of Commons in September 2016.
The demise of both Bill C-290 and Bill C-221 means that the current parlay system remains in place. Both C-290 and C-221 were Private Member’s Bills (PMBs).
Bill C-218 & Current State of Sports Betting Across Canada
The Safe and Regulated Sports Betting Act, first introduced by Kevin Waugh, MP for Saskatoon-Grasswood in February 2020 as a Private Member’s Bill, passed the House of Commons with all-party support on a recorded vote of 303-15 at Second Reading one year later.
The House of Commons Justice Committee heard from 32 witnesses and received 29 briefs, all in support of the Bill, including the horse racing industry which asked for and received greater protection.
Bill C-218 reached the Senate in June 2021. Thanks to the efforts of the Bill’s sponsor, Senator David Wells, C-218 passed without amendment on Third Reading on June 22, 2021. Single-event sports wagering became legal across Canada on August 27, 2022, and it is up to each province to determine which products to offer and how. Archived documents relating to C-218 are available here.
Cullen Commission on Money Laundering
The Cullen Commission of Inquiry into Money Laundering in BC was launched by the provincial government to examine the extent, growth, evolution, and methods of money laundering in various sectors such as gaming and horse racing, real estate, financial services, luxury goods and professional services including legal and accounting. The CGA was granted standing to ensure the gaming industry is evaluated and considered in fair and factual manner.
The work of the Commission directly affects the interests of the CGA and its members, as the Commission’s Terms of Reference empower the Commission in Section (2)(a) “to make recommendations the commission considers necessary and advisable, including recommendations respecting the following: i. the regulation of [gaming and horse racing]”.
The CGA through its submission outlined the Canadian gaming industry’s commitment to AML best practices, continuous improvement including the examination of emerging technologies, and learnings from jurisdictions outside of Canada.
The CGA earned standing with this Commission in 2019, provided background on the Canadian gaming industry, and participated in the opening hearings in February 2020. In June 2022, the CGA released a statement on the Cullen Commission’s final report.
You can read the CGA's two statements (February 2020 and June 2022) below.
ALC Supreme Court of Canada Decision Atlantic Lottery Corporation Inc. v. Babstock
The CGA applauds the Supreme Court of Canada’s decision not to allow a class action lawsuit about video lottery terminals (VLTs) to go forward.
The Court's decision can be found here.
The CGA was granted intervenor status in 2019 in the Atlantic Lottery Corporation Inc. v. Babstock in support of the appellants, the Atlantic Lottery Corporation and its VLT and software suppliers and was represented by McCarthy Tétrault LLP.
The Court unanimously echoed a couple of the CGA’s key submissions, and we are pleased the Association was able to support our industry, and that the perspective of the Canadian gaming community was considered so that the Supreme Court was able to release a principled decision that benefits the industry.
Brandon Kain, Partner at McCarthy Tétrault LLP, who successfully defended our industry, had these insights to share:
"For the CGA and its members, the most significant outcome of this decision is the Court’s narrow reading of the offence-creating provisions of the Criminal Code. The Court unanimously rejected the plaintiffs’ proposed interpretation, which would have made all VLTs and similar gaming offerings legally suspect. CGA members can also take comfort in the Court’s conclusions with respect to disgorgement, breach of contract, and good faith. Each of these will make it difficult or impossible for plaintiffs to certify class actions based on allegations that a gaming offering somehow did not provide players with what they paid for, without establishing – or at least asserting – that the players suffered a legally compensable loss as a consequence."
The CGA’s Regulatory Innovation Committee developed regulatory standards for cashless wagering in land-based Canadian casinos in 2020 which are now available for implementation across Canada. The committee was created as a platform for industry and gaming regulators to engage in two key areas: the adoption and utilization of emerging technologies; and on regulatory initiatives in the areas of harmonization and operational efficiency. It includes a cross section of gaming industry representatives working with provincial gaming regulators and subject matter experts.
The Regulatory Innovation Committee moved on to sport and event wagering standards in 2021 given the legalization of single-event sports wagering.
Building upon the successful work in 2020 and 2021, a subject matter expert sub-committee was created to tackle the AML project that it identified for 2022.
The committee provided feedback, as well as several industry papers, to the federal Ministry of Finance on proposed improvements to the Proceeds of Crime (Money Laundering) and Terrorist Financing or PCMLTF Act as part of the Government of Canada’s 5-year review of the Act expected to begin in 2023.
In August 2023, the CGA provided a 13-page submission: Consultation on Strengthening Canada's AML & ATF Regime.
There is a need to have the PCMLTF Act better reflect the evolution of Canada’s gaming industry and allow for continued strong compliance. We expect to pick this work up again throughout 2024.