Listed Person or Entity Property Report: Casino Guide

A casino must send a listed person or entity property report (LPEPR) to FINTRAC immediately once it is required to disclose property owned or controlled by a listed terrorist group or sanctioned person. It replaced the Terrorist Property Report on 2 March 2025, with wider scope from 1 October 2025. Chips, tokens, player accounts and virtual currency count as property.

This guide maps FINTRAC's sector-neutral rules on the Listed Person or Entity Property Report (LPEPR) to a casino floor and an online casino account. It covers what changed from the old Terrorist Property Report, the four legal triggers, what counts as property, an ordered response workflow, how to submit, which lists to screen, and how the LPEPR sits next to a suspicious transaction report and a casino disbursement report. The main source is FINTRAC's guidance on reporting terrorist property and sanctioned property (Guide 5, date modified 1 October 2025), opened on 14 November 2026. This is a general explainer, not legal advice; confirm your obligations with FINTRAC and counsel. Gambling is for adults only (18+ or 19+ depending on province); if play stops being fun, contact your provincial responsible gambling service.

What the Listed Person or Entity Property Report is (and what it replaced)

For years, casino teams knew this obligation as the terrorist property report casino requirement. FINTRAC published updated guidance on 28 February 2025, and law firm DLA Piper's alert of 18 March 2025 summarised the change: the report now covers sanctioned property as well as terrorist property, the definition of property now expressly includes physical goods, and the deemed-ownership rules under the sanctions laws reach further than simple majority control. The new name, Listed Person or Entity Property Report, reflects that wider scope.

The old name is still around. Teams searching for the terrorist property report FINTRAC guidance will find archived pages, and FINTRAC's own casino record keeping page (modified 2022-04-27) lists the new report name but still says "TPR" in its retention note for that report copy. Treat any internal procedure that says "Terrorist Property Report" as out of date and update it to the LPEPR wording, triggers and lists below.

The obligation applies to all reporting entities under the PCMLTFA, so casinos are covered in the same way as banks, dealers and money services businesses. Unlike most casino reports, it has no dollar threshold and does not need a transaction. It is triggered by the existence of property owned or controlled by a listed person or entity, which is why it depends on screening your players. If you rely on a vendor for that, compare KYC and AML providers with sanctions screening for casinos on list coverage and decision logging.

When a casino must file: the four legal triggers

Guide 5 says you must submit an LPEPR when you are required to make a disclosure under any of four laws:

• Criminal Code s.83.1, for property of terrorist groups;
• orders or regulations under the United Nations Act;
• orders or regulations under the Special Economic Measures Act (SEMA);
• s.7(2) of the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

No transaction has to happen. If a listed person holds a funded player account and never logs in again, the property still exists and the duty still applies.

Phase-in: March 2025 and October 2025

The scope widened in two steps. For a casino, the practical point is that sanctions screening which only covered terrorist listings before October 2025 is no longer enough for this report.

Source: FINTRAC Guide 5, date modified 1 October 2025.

What counts as property in a casino

FINTRAC defines property as anything owned or controlled, tangible or intangible. Its list includes cash, monetary instruments, casino products and tokens, virtual currency, accounts, prepaid payment products, securities, jewellery and precious metals and stones, real estate, insurance policies and physical goods. For a casino, that covers most forms of player value.

Land-based floor

Chips, tokens and plaques in a player's hands, front money on deposit, safekeeping deposits and cash at the cage are all property.

Online accounts and virtual currency

For an online operator, the obvious case is a funded player wallet. As an illustration: if screening shows that a verified account holder matches a listed person, the account balance is property that person owns or controls, whether or not they are playing. Virtual currency held for the player, and pending withdrawals, fall in the same bucket.

Step-by-step: what to do on a list match

Guide 5 sets out what has to happen once you know you hold listed property. The order below is our casino workflow built from those requirements.

1. Stop the related transaction

FINTRAC advises that you should not complete a transaction you know relates to property of a listed person or entity. At the cage that means no chip redemption or payout; online it means no withdrawal or transfer out of the account. Our guide to casino disbursement reports covers the same point from the payout side.

2. Disclose to the RCMP and CSIS

Disclose without delay to the Commissioner of the Royal Canadian Mounted Police (RCMP) and the Director of the Canadian Security Intelligence Service (CSIS). The disclosure includes the property and any related or proposed transactions.

3. File the LPEPR immediately

FINTRAC's word is "immediately", meaning there should be no delay before the report is submitted. Do not wait to finish an internal review before filing once the duty to disclose exists.

4. Assess an STR

If a transaction involving the listed property was attempted or completed, assess whether a suspicious transaction report is also required. The two reports do different jobs and one does not replace the other. Our guide to suspicious transaction reports in casinos explains the STR test and content.

5. Keep the copy

Keep a copy of each LPEPR for at least five years from the day it is sent. An electronic copy is fine if a paper copy can be readily produced. Because FINTRAC sends no acknowledgement, also keep your fax confirmation or proof of mailing with the copy.

How to submit: form, fax and mail

The FINTRAC LPEPR is a paper report. Guide 5 lists these channels:

• Use the printable LPEPR form, or request a form by phone at 1-866-346-8722.
• Send it by fax to 1-866-226-2346 if possible.
• If fax is not possible, mail it to FINTRAC, Section A, 234 Laurier Avenue West, 24th floor, Ottawa ON K1P 1H7.

Guide 5 does not mention an online or API channel for this report, so do not build your workflow around one. FINTRAC does not send an acknowledgement of receipt.

Because the form is manual, prepare the internal file before you fax it: who confirmed the match and when, which list and listing it matched, what property you hold and its value or quantity, any related or proposed transactions, and the time of the RCMP and CSIS disclosures. That file supports the five-year copy and answers the first questions an examiner is likely to ask.

Which lists to screen against

A sanctioned property report for a casino in Canada is only as good as the screening behind it. FINTRAC's guidance points to four sources:

• the UN Security Council Consolidated List;
• the Schedule to the UN regulations on the suppression of terrorism;
• the Consolidated Canadian Autonomous Sanctions List;
• Public Safety Canada's list of currently listed terrorist entities.

Screen at onboarding and again whenever a list changes, and log each match decision, whether it was a true match or a false positive. Our guide to PEP, sanctions and adverse media screening covers how screening tools handle name matching. When you assess a screening vendor, check that it covers all four lists and keep the decision log you will need for the five-year record.

LPEPR vs STR vs casino disbursement report

Casino teams often ask which report applies. A single event can trigger more than one. The table compares the three, using FINTRAC Guide 5, FINTRAC's STR guidance and PCMLTFR s.71.

Two points stand out. First, the LPEPR is the only one of the three with an "immediately" deadline and an outside disclosure to the RCMP and CSIS. Second, if the listed property was involved in an attempted payout, you may face all three questions at once: the LPEPR is required, the payout should not be completed, and an STR has to be assessed. Write that sequence into your procedures before it happens at the cage.

For the official wording, read FINTRAC listed person or entity property reporting guidance, and update any procedure that still calls this the Terrorist Property Report.

18+ only. Gambling can be addictive — please play responsibly and only bet what you can afford to lose. If gambling is affecting you or someone you know, contact a local support service. This content is informational and never a guarantee of winnings.

Written and reviewed by the iGaming Expert Hub editorial team. Facts checked against primary sources; see the reference above.

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