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Thrive Liquor & Cannabis Advisors recommends ongoing LCRB compliance audit for good reasons.
Not only do LCRB compliance inspectors make unannounced visits to licensee businesses, minor agents also randomly check licensee establishments.
What is the LCRB Minors as Agents Program (MAP)?
The Minors as Agents Program had its beginnings in 2003. The pilot project ran for five years and the results were startling. The compliance rate was less than 1/3. Because the agents were “youthful-looking adults”, LCRB couldn’t take action against businesses who failed to ask for ID and sold liquor to the agent. In 2010, in response to the pilot findings, LCRB established the “Minors as Agents Program”. The Liquor Control and Licensing Act was amended to allow the BC government to employ minors as agents who could attempt to purchase alcohol.
Source: “Liquor Control Act Enforcement: What is the Minors as Agents Program? ”, Alcohol & Advocacy, November 2014.
Though the article cited above was published a decade ago, it’s just as relevant today. Minor agents are watching, and not just liquor stores. The Cannabis Control and Licensing Act also allows minor agents to enter licensed cannabis stores and attempt to purchase cannabis or cannabis accessories.
Whether you run a liquor store, wine store, cannabis store, bar, manufacturer’s lounge, or restaurant, your business may be randomly targeted by minor agents.
Do I Really Have to Worry About Underage Secret Agents?
Yes!
In the LCRB Waivers Summary Report Jan 1, 2023 – June 30, 2023, 172 LCRB licensees signed a “waiver” (admitted to a contravention) and accepted the penalty imposed. 59/172 licensees were in contravention of the prohibition of sales to minors – a $7000 penalty. To see the contravention, you can search for “7000”, “Sell, give or otherwise supply liquor to a minor”, or “Sell cannabis or cannabis accessories to a minor”.
To see a list of licensees who appealed the Notice of Enforcement Action (NOEA), view this spreadsheet.
In the spreadsheet, “Paul Esposito’s Restaurant” in Abbotsford is an example of a licensee who successfully appealed the alleged contravention of Section 77 of the Liquor Control and Licensing Act “Selling liquor to minors”.
If you’re curious about a minor agent’s perspective, read the Vancouver Magazine article “What’s It’s Like Buying Booze as a Minor for the B.C. Government?”. In the article, an ex-agent (agent “006” no less), recounted his experiences as an underage secret agent in the program. Just like an agent in a spy thriller, Agent 006 had handlers, one in the store and one awaiting in a car, as he entered the store on a “mission”.
Now an adult, the ex-agent has misgivings about the job, saying “I felt cool—but people’s careers were at stake when they sold to me”, adding “And if everyone knows about it, that should work in the government’s favour—the goal is to prevent alcohol sales to minors, right?”
Forewarned is forearmed.
LCRB Compliance Audits & Training from Thrive Advisors
Thrive Liquor & Cannabis Advisors provides many licensing and operational services for liquor and cannabis businesses that help ensure continued compliance with LCRB terms and the law. Due diligence should be taken seriously. Ignorance of the Minor as Agents program or other license requirements are not a defense against LCRB enforcement action.
