Silver and Gold: A Tale of Underground Casinos and Government Complicity
by Sam Cooper, excerpted from Wilful Blindness
It was September 15, 2017, and I was seated across from Harold Munro, the editor-in-chief of the Vancouver Sun, and Hardip Johal, the feature story editor, in the Sun’s editorial boardroom. I had just rambled through a laundry list of evidence, which must have sounded incredible. A vast story had come together very quickly — threads I had been following for years. And I was struggling to explain it all.
In early 2017, I had been guided towards B.C. Gaming Enforcement Branch intelligence documents on a casino-money-laundering network involving Mainland China real estate developers I had been investigating.
A B.C. government source had sent this email: "Lap Sang Peter Pang is connected to Big Circle Boys. You may also want to look at a guy by the name of Paul King JIN and also Kwok TAM. Big crime figures in Richmond. Suspects in illegal gaming, extortion, loan sharking, drug trafficking, and underground banking. Also acquiring real estate."
I had made a number of freedom of information requests based on these tips, and I was expecting to receive a massive cache of GPEB documents within days. But after meeting with [whistleblower] Ross Alderson on September 12, I already had a tremendous amount of evidence.
Sitting in a coffee shop near the Hotel Fairmont with a view of Victoria’s Inner Harbour, Alderson and I had talked about the RCMP’s investigation into Paul Jin. We discussed how Alderson’s team had made property ownership maps in Richmond and Vancouver. They found pockets of extreme wealth where the Big Circle Boys and Mainland China VIPs owned lots of land. Mansions sprawled across Richmond farmland were running illegal casinos, according to Alderson’s intelligence.
The illegal casinos and B.C. Lottery casino loan sharks were directly connected. Alderson told me that many millions in high-value casino chips had gone missing from River Rock Casino. This was essentially B.C. government currency that flowed between Richmond illegal casinos and government casinos. It was a store of value for organized crime underground banks in Vancouver and China. And it was much easier to carry a purse with 40 chips worth $5,000 apiece than a hockey bag with $200,000 worth of $20s wrapped in elastic bands.
We discussed how Alderson perceived political connections between Mainland China high-rollers and officials in China.
I also knew that some police believed transnational organized crime had corrupted portions of B.C.’s establishment.
And Alderson told me there was an RCMP intelligence theory that Paul Jin had links to the Chinese Communist Party. He said he found the theory hard to believe at first. But the idea gained credibility in 2017 after Richmond real estate lawyer Hong Guo directed a police “investigation” in Zhuhai that led to arrests of Guo’s employees Qian Pan and Zixin Li.
The information we were discussing pointed to a scandal worthy of a public inquiry. So when I returned to Vancouver, Alderson arranged to transfer classified documents. These were official government records about investigations into Paul Jin and the Chinese VIPs. The numbers were massive. The operation was worldwide. It was the story of a lifetime.
Harold Munro had been an investigative reporter before rising to the top editorial position for the Vancouver Sun. In my experience, Munro loved big, hard-hitting stories. And the bigger the story, the harder his vetting questions. He would come at you like a lawyer, looking for weaknesses. So, in this story meeting on September 15, I was trying to boil down incredibly complex information. And Munro seemed to be losing patience. I could imagine what was going through his mind: "How the hell can we prove this?"
After some cross-examination, we were at an impasse. I took a deep breath, pulled a sheet of paper from my binder, and shoved it across the table to Munro. It was a Section 86 report. The legal form must be filed to GPEB whenever Lottery Corp. staff learn of potential crimes. This was Alderson’s unredacted July 2015 brief on the Paul Jin “Silver” investigation.
Munro started to read the document with a frown. And I sat waiting. The report was just a few paragraphs. But each sentence was weighty. Within about 30 seconds, Munro’s mood had brightened considerably. And when he finished reading, he was smiling.
We talked about Alderson’s documents and how they would be buttressed by the GPEB records due to arrive any day. Munro told me to drop all my other stories and focus on the B.C. casino files. No one outside of the story meeting knew of the explosive records I had. At the same time, we didn’t know B.C.’s government was battling internally over my GPEB disclosure case.
The conflict revolved around an audit of River Rock Casino commissioned by GPEB and completed by the forensic accounting firm MNP. This was a high-level report on the problems that allowed suspicious cash to flood B.C. casinos. Really, it was an accountant’s overview of the RCMP’s Jin investigations. For months, I had been negotiating to obtain this report and thousands of related GPEB records.
Silver and Gold: Turmoil in B.C.'s Lottery and Casino Industry
For some reason, B.C. Attorney General David Eby had decided to release the MNP audit to all media outlets ahead of my legal disclosure request. And B.C. Lottery Corp. executives panicked.
An email chain I later obtained through a freedom of information request showed their efforts to “modify” the MNP audit. On September 20 at 5:59 p.m., Lottery Corp. board chair Bud Smith—a former B.C. attorney general—emailed Lottery Corp. CEO Jim Lightbody and chief of compliance Robert Kroeker.
“Colleagues, I just took a call from the Minister’s office. Apparently, the FOI process is about to release the MNP report on ML [money-laundering],” Smith wrote. “The Minister wants to release it himself and phoned to give a heads up. I said send what is going to be released, and if it’s what I think it is, there’s an Ernst and Young report, and I believe a Fintrac report that was done around the same time and likely modified some of the MNP conclusions.”
Lightbody emailed back: “Bud, the Minister’s [assistant] also called me, and it is the MNP audit. It doesn’t include our management response, which is a problem. The report is challenging at best. It was commissioned by GPEB.”
The email chain shows that Kroeker—River Rock Casino’s chief of compliance from 2011 to August 2015—pushed back on MNP’s conclusions. “The MNP audit covered the period from September 2013 to August 31, 2015,” Kroeker wrote. “This audit focused on only select transactions at River Rock. We were not consulted by GPEB prior to the FOI package going to the Minister—certainly I was not given an opportunity to comment on redactions.”
Kroeker would later testify in B.C.’s money-laundering inquiry that while he was in charge of compliance at River Rock, feedback from Fintrac on BCLC’s money-laundering controls was positive, and Great Canadian “continually endeavored to improve its controls.”
Meanwhile, panicked emails to Eby’s staff about MNP’s audit continued. “Sam [Godfrey], I’ve reviewed the [MNP] document you sent,” Lightbody wrote on September 20. “We are very concerned that the report does not include our management response that we provided, which is the usual practice and provides balance and perspective.”
On Thursday, September 21, I learned that the MNP audit—part of my FOI request—would be released publicly Friday morning. I had been working on the underlying story for months. And now bureaucrats were trying to manage how the information would be disseminated. I had no idea the Lottery Corp. brass was trying to undermine the MNP report. But I was concerned.
I called a government official Thursday evening and complained. There wasn’t much I could do. But it was arranged that an embargoed copy of the MNP report came to me that night.
The report was heavily redacted and named no names. But it was obvious why the Lottery Corp. hated it. GPEB had commissioned the MNP audit because an investigation “identified approximately $13.5 million in $20 bills being accepted in River Rock in July 2015.”
And MNP’s audit tied the funds to the Richmond casino loan sharks and “high-roller Asian VIP clients.”
The report said River Rock’s staff had “fostered a culture accepting of large bulk cash transactions,” and because the VIPs were from China, it was difficult for staff to judge the legitimacy of their wealth.
“Chinese nationals… comprise the majority of the identified high-risk demographic at River Rock,” the audit said. “Interviews have confirmed that VIPs are indeed wealthy non-residents or business persons with interests in Vancouver and China, coming to Vancouver to gamble. The use of possible underground banking operations using large volumes of unsourced cash have become increasingly common and accepted as a convenience feature for VIP players who may not be able to send funds to Canada.”
And it was all about B.C.’s government turning a blind eye to suspicious money.
“Accepting large volumes of cash has been a growing problem in the province for a number of years,” the report said. “BCLC is accountable to the province for revenue… Service providers [are] focusing on revenue.”
I broke the MNP audit story Friday morning. But my real work started on Saturday morning. I had documents that named names. I had ultra-confidential Fintrac records. I could connect the Big Circle Boys casino loan sharks and Chinese whales to major real estate lending networks. I could pull back the curtain on a scam that had been covered up for decades. I could tell the story of the largest RCMP money-laundering investigation in Canadian history. And we had a week to pull it together.
The Vancouver Sun front page exclusive ran on Saturday, September 30, and I started the story like this:
“On Oct. 15, 2015, a Mountie burst through the front door of an office in Richmond, carrying a battering ram and with a rifle slung on his back. The door swung shut behind him, locking him inside. He was in the lobby of Silver International Investment, a high-end money transfer business, surrounded by bulletproof glass.
“Behind a second glass door, a woman rushed to make a call while hiding several cellphones. Under her desk was a safe stuffed with bundles of cash. The Mountie, a large man, counted seconds anxiously, wondering if the woman would unlock the interior door.
“It was one of 10 police raids in Richmond that day—part of a major investigation that has uncovered massive money-laundering and underground banking networks with links to Mainland China, Macau, and B.C. casinos, allege the RCMP’s federal organized crime unit and China’s national police service.
“Now, the inside story can be told of the investigations that led B.C.’s attorney general last week to order an independent review of casinos overseen by the B.C. Lottery Corp.”
The story focused on Paul King Jin. I have never been able to interview him after repeated attempts to reach him through lawyers.
But Jin has left a massive trail of incriminating records. Through dozens of interviews with people in business and law enforcement, and after obtaining and studying many thousands of government, legal, and corporate records dating from the early 1990s to 2020, this is what I learned about Paul Jin’s background and function in a global criminal network that extends all the way to Beijing.
“There was a large third-party buy-in [in late 2017] where a brand new patron walked in with $200,000 in $100 bills and waited to receive chips. Once the chips were delivered, the patron left the casino without any play,” MacGregor’s report said. “This incident is being investigated for regulatory infractions at the River Rock Casino … This incident is highly suspect, and the ongoing GPEB investigation into this matter is the first step in identifying the correlation of connections between service provider staff, local patrons, foreign patrons, and illicit activity.”
Still, in late 2017, the RCMP had only limited knowledge of who the Silver VIPs were.
“When we take down an elephant, or in this case a whale, we digest one leg at a time,” is how a senior RCMP officer put it to me.
But in 2019, when Alderson summed up his findings in notarized filings, he presented a more definitive portrait of the Silver whales. He wrote that during 2014 and 2015, while B.C.’s fentanyl crisis was evolving into a public health emergency, Lottery Corp. casinos were accepting from $17 to $22 million in suspicious cash transactions per month.
“Being in charge of Lottery Corp. investigative and intelligence groups, I gathered evidence that many of the industry VIP players were involved in criminality, including the drug trade as well as suspected money laundering in real estate, casinos, and other sectors,” Alderson wrote. “There was also evidence of political involvement by a number of these individuals. And there were indications of government interference in enforcement and possible corruption.”
So on October 15, 2015, Bruce Ward’s unit raided ten locations in Richmond, including Silver International Investment, in the office tower at 5811 Cooney Road. It was an extremely successful raid in most aspects.
Silver was a high-tech operation. The RCMP seized 132 computers and cell phones, transaction ledgers, safes and money counters, over $7 million in cash, and security camera footage that captured massive cash exchanges in cinematic detail.
“We were very lucky because one surveillance team started the file, but they didn’t have an understanding of what was going on inside,” Ward explained on my secret audio recording. “We didn’t have a chance to use covert teams to see the inside of the business. But they had their own internal security system, and we were able to seize two weeks of their tapes.”
Over 1,000 pages of RCMP surveillance and seizure records filed with the Cullen Commission outline the moving pieces of Jin’s operations in stunning detail. Police seized many banking records and real estate promissory notes and mortgages from Jin’s properties. They also collected legal documents prepared by Hong Guo. These were the legal registration papers that Jin and his wife, Xiaoqi Wei, allegedly used to take collateral against Vancouver mansions for massive cash loans. One of the real estate documents seized from Jin was a $1.2 million promissory note from one of Jin’s River Rock VIPs. Jin’s wife was interviewed about the lawyer involved.
“So the time that Paul didn’t get his money back, did they pay him back eventually?” a Vancouver police detective asked her.
“Not always,” Wei answered. “Sometimes, some person just gives their house to us.”
“So [Hong Guo is] the lawyer that helps facilitate or helps arrange the signing?”
“Yeah,” Jin’s wife answered.
Surveillance records showed Jin dropping into Guo’s office several times, as he made his daily rounds in fleets of vehicles, taking bags in and out of restaurants, withdrawing suitcases of cash from Silver, making drops and exchanges in parking lots, and running in and out of the Water Cube Spa, where Jin’s illegal casino clients came to pay when they lost on the credit they drew in his gaming dens.
The RCMP also seized “invoices with score sheets” in garbage bags, records from RTY Financial, and receipts from West Coast Hunting. When a police dog searched five vehicles seized from Jin — including a Bentley Continental, a red Porsche 911, and a white Toyota Sienna — all tested positive for narcotics residue. Surveillance records showed that for one complex transaction in a Richmond Costco parking lot, a vehicle registered to YZ — an alleged fentanyl trafficker involved in real estate lending with Jin — appeared to make counter-surveillance maneuvers before a bag was exchanged from the trunk of one of Jin’s vehicles.
There was an incredible amount of evidence. But back in October 2015, there were already troubling signs for an investigation that would ultimately implode.
The underground banking portion of the raid caught staff allegedly red-handed. But strikes on illegal casinos did not.
“They had two ongoing illegal casinos where the same businessmen who were part of the conspiracy provided non-government gambling for these offshore gamblers,” Ward explained while showing images of two luxury properties. “These are some of the illegal casinos he was setting up. Each of these places had significant security cameras and systems. When we did our takedown, one place was closing down.”
Four days later, on October 19, Alderson heard from a senior B.C. police officer that the RCMP was concerned that the Lottery Corp. had interviewed whale gamblers in Jin’s network ahead of the raid on a sprawling hacienda on over 20 acres of secluded farmland on No. 4 Road, in south Richmond. It was the city’s second-most valuable property, worth about $10 million. The RCMP seemed to be questioning whether the Lottery Corp. had leaked plans to VIPs, who then communicated to Paul Jin about the upcoming raid on the Big Circle Boys casino.
The underground casino on No. 4 Road, complete with tennis courts, swimming pool, and six full bathrooms, had 29 surveillance cameras. And it was hastily abandoned.
“Discussed sensitivity in sharing information as the operation was compromised,” Alderson’s notes from the meeting with a senior B.C. police officer say. “No. 4 Rd. location had the original warrant date (Oct 14) circled on a calendar. Concerns Govt knew more than Senior Police did.”
But it wasn’t clear from Alderson’s notes who could have leaked the raid plans.
“Talked about how any info Govt had was through RCMP except for the list of players and the locations of gaming houses that were given to GPEB,” Alderson’s notes say. “We were aware of briefing notes written to the Minister. Agreed that interviewing players highlighted JIN’s involvement; however, locations of Gaming Houses were all provided to GPEB. Agreed that a lot of people had inside knowledge of this operation but reiterated no one (to my knowledge) knew of any dates of the operation.”
So, according to Alderson’s 2015 records, it looked like a Mainland China drug cartel with possible connections to Chinese officials had accessed the most sensitive police intelligence and operational details held by the RCMP, in Canada’s largest-ever transnational money-laundering investigation. As far as Alderson knows, there is still no indication of who was responsible.
“After a series of police raids on illegal gaming houses had been conducted in Richmond, B.C., I was party to conversations where there was a belief by some members of law enforcement that the raids had been compromised by a leak,” Alderson wrote in 2020. “Possibly within their ranks, or within government.”
The fact that the Big Circle Boys may have had access to Canada’s most sensitive law enforcement plans is tragic. But considering the sheer scale of Silver’s alleged operations and its clientele in China, Mexico, and Iran, it is terrifying.
In his 2017 presentation, Bruce Ward explained the opposite arm of Silver’s cash lending services for whale gamblers. It had evolved into a financial juggernaut allegedly capable of laundering and moving over $1 billion per year for the import and export of drugs. All of this emanated from an office tower in downtown Richmond.
While playing video evidence, Ward explained how drug dealers could instantly make their mountains of dirty cash in Canada materialize in bank accounts in China, Mexico, or Peru. It started with a phone call and a visit to the criminal vault. A single woman stood behind a desk with a cellphone and a ledger. That was it — no bodyguards with guns.
“This is a typical event of a drug dealer bringing in cash,” Ward said as a video clip played. “She receives a call, she goes out to receive a trusted customer. There are $100s and $50s. But the vast majority are $20s. The relationship is such, and trusted, that the phone call is made: ‘I’m coming in with’ — in this case, it was $1.4 million. And the staff will wire transfer the credit for that in China before the cash even comes in the door.”
In other words, as Silver recorded a cash transaction in the ledger of its Richmond criminal bank, it would simultaneously send instructions electronically to credit the drug dealer’s bank account in China with a fund transfer from one of Silver’s bank accounts in China.
Bruce Ward’s video clip showed the drug dealer dropping his duffel bag of cash in Silver’s Richmond office. “She counts it by hand,” Ward said, “writes it down in her ledger, double checks the money is the same that they said by phone. Five minutes later, it’s the end of her shift. She walks out and locks the door. There is no security because no one would know it is there or dare rob that place.”
According to the RCMP’s forensic investigation, Silver turned $220 million in drug cash into bankable instruments in Canada in its first year. Most of this was laundered through B.C. casinos and whales. But $20 million of the cash was provided to downtown Richmond currency exchanges. It was an excellent illustration of how the Big Circle Boys have slowly infiltrated banks in Asia by co-mingling clean and dirty money.
“This definitely causes concern, and it is a bigger issue in the future. Because this is a legal business of transferring money on behalf of you and everyone else between countries,” Ward said on my audio recording. “How they do that is they have a safe with cash under the till. Your grandma wires you $30,000 for your birthday. You go into that business, and they could send the $30,000 to your bank electronically. Or, they will give you cash [and give the customer a premium].”
“So you get $31,000 (cash). So, where do they legally get their cash? From the banks. But where do they illegally get their cash? [From organized crime.] How do we tell the difference?”
So Silver had mastered laundering illegal casino, extortion, prostitution, and drug cash through B.C. casinos and real estate, using whales that wanted to invest their Chinese wealth in Canada.
But Silver’s move into narco supply chain logistics — also connected to China’s biggest whales — appears to have been its highest growth business. When the RCMP took the Richmond underground bank down, it had already set up over 600 bank accounts in China, and the accounts were multiplying exponentially.
“What Silver started to move into is facilitating the purchase and importation of the drugs,” Ward said, pointing to transaction records. “This is a typical request. A direction from Silver International to move money from their own account to a drug dealer’s account. We saw evidence of over 600 accounts in China that were controlled or fed by Silver International. So they would do that on your behalf. They would open up an account in China. You give them $100,000 cash in Richmond, and they wire transfer you $95,000 into your account in China.”
Talk about a disruptive innovator. In Vancouver, drug dealers with fentanyl precursor suppliers in Wuhan or Guangzhou could have Silver wire transfer funds to cartel accounts in China. These funds would result in more fentanyl arriving in Vancouver. Drugs would be sold, cash collected, funds wired to China, and the cycle repeated. If these dealers had cocaine suppliers in Mexico or Peru, they could have Canadian banks wire transfer funds to drug dealer accounts in Latin America.
This way, the trafficker selling in Canada could buy drugs in Latin America or China without assuming the risk of packing cash into a suitcase and boarding a plane. Fake trade invoices from Chinese manufacturers covered the wire transfers. It was the Chinese organized crime variation of what the FBI and DEA call the black market peso exchange.
This is also known as trade-based money laundering, in which drug shipments are made to look like legitimate products or co-mingled with legitimate products. To the bank, it looks like a North America-based importer-exporter is buying something like T-shirts, coffee beans, or electronics, when they are really buying cocaine or fentanyl.
“If you work for banks, you are facilitating money laundering,” Ward told his audience while pointing at a Silver wire record. “They are sophisticated enough, they will hide this behind false invoices. I am paying an invoice to somebody from China who supposedly sold me something. I am paying for it, in this case, to Peru. Then the supplier will release, for transport, the narcotics.”
This all meant that Vancouver had become a global tool for buying, selling, and shipping cocaine, heroin, methamphetamines, and fentanyl, and rinsing the proceeds in local and international real estate.
And it wasn’t just the Big Circle Boys and Chinese whales using B.C. to operate. My RCMP sources would discover the world’s most violent narcos, including Joaquín “El Chapo” Guzmán’s Sinaloa cartel, and narco-terrorist networks connected to Iran were multiplying in Vancouver and using Silver’s brilliant money-laundering machine.
So, as I broke story after story in late 2017, the RCMP and B.C. government were in a tough position. They had no control over the information. I knew police believed Chinese transnational gangsters had corrupted significant portions of B.C.’s establishment. It wasn’t just Lottery Corp. casinos that police were worried about.
The RCMP wanted to hold a press conference to inform Canadian citizens about what they learned in E-Pirate. But when senior police officials briefed NDP government officials on the plan, the press event was cancelled.
“On September 20 at 5:59 p.m., Lottery Corp. board chair Bud Smith—a former B.C. attorney general—emailed Lottery Corp.”
No conflict of interest there, eh?