1. Purpose and Scope
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy sets out the requirements that apply to Cascades Casino Chatham as a reporting entity under Canadian law. It defines the obligations of the casino and its customers in relation to identity verification, customer due diligence, transaction monitoring, record keeping, and reporting.
This Policy applies to all individuals who access gambling services at Cascades Casino Chatham in a land-based capacity and to any qualifying online activity where applicable. It is established in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), its regulations, and the regulatory guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
All staff, compliance officers, and relevant third-party service providers are required to adhere to the procedures and standards described in this Policy.
2. Legal Framework
2.1 Governing Legislation
The primary legal basis for this Policy is the PCMLTFA and its associated regulations. Cascades Casino Chatham is subject to oversight by FINTRAC and must comply with applicable guidance, including FINTRAC’s published indicators and sector-specific documents for money laundering and terrorist financing risks in casinos.
2.2 International Standards
Where relevant, this Policy takes into account the recommendations of the Financial Action Task Force (FATF) relating to anti-money laundering and counter-terrorist financing programs.
3. Know Your Customer (KYC) Requirements
3.1 Customer Identification
Prior to engaging in gambling activity or conducting transactions that meet or approach applicable reporting thresholds, customers are required to provide valid identification. The following information must be collected and verified:
- Full legal name
- Date of birth
- Residential address
- Government-issued photo identification document
Acceptable identification documents include a valid passport, provincial driver’s licence, or other government-issued document that includes a photograph and date of birth. Documents that are expired, altered, forged, or inconsistent with other information provided by the customer will not be accepted.
3.2 Age Verification
No individual under the minimum legal gambling age of the applicable jurisdiction may participate in gambling activity. Age is verified as part of the standard customer identification process. Where age cannot be confirmed, access to gambling services is denied.
3.3 Enhanced Due Diligence
Customers identified as presenting a higher risk profile are subject to enhanced due diligence (EDD). This may include:
- Verification of source of funds (SOF)
- Verification of source of wealth (SOW)
- Review of financial records, bank statements, or other supporting documentation
- Increased frequency and intensity of ongoing monitoring
High-value players, VIP customers, and individuals whose transaction patterns indicate elevated risk are subject to EDD procedures. Documentation collected under EDD is retained in accordance with the record-keeping requirements in Section 6 of this Policy.
3.4 Ongoing Customer Due Diligence
Customer due diligence continues throughout the customer relationship. Ongoing monitoring includes:
- Periodic review of customer profiles
- Reassessment of risk classification
- Updating of identification records when information has changed or become outdated
Where changes in behaviour, transaction patterns, or other relevant factors are identified, the risk profile may be adjusted and additional measures may be applied.
4. Anti-Money Laundering (AML) Controls
4.1 Risk-Based Approach
A risk-based approach is applied to AML compliance. Customers are assigned to risk tiers based on factors that may include transaction volume, deposit and withdrawal patterns, geographic risk, product and channel risk, and behavioural indicators. The level of monitoring and due diligence applied corresponds to the assessed risk.
4.2 Transaction Monitoring
Customer transactions are subject to automated and manual monitoring designed to identify patterns and behaviours consistent with money laundering or terrorist financing, including those set out in FINTRAC’s casino-related indicators.
Transactions subject to heightened scrutiny include, but are not limited to:
- Large cash deposits or withdrawals at or near reporting thresholds
- Multiple transactions structured to remain below reporting thresholds
- Deposits followed by minimal or no gambling activity and subsequent withdrawal requests
- Inconsistent deposit and withdrawal methods, including deposits via prepaid instruments followed by wire transfer withdrawals
- Withdrawals directed to third-party accounts or accounts in high-risk jurisdictions
- Use of multiple accounts by the same individual or by associated individuals sharing identifying information such as an IP address or device
Where unusual or suspicious activity is identified, further review and escalation procedures are applied.
4.3 Red Flag Indicators
In accordance with FINTRAC guidance, the following behavioural and transactional indicators are incorporated into internal monitoring procedures and may trigger further investigation or the filing of a suspicious transaction report:
- Refusal to provide required identification or source of funds information
- Provision of false, inconsistent, or obviously fabricated personal or financial information
- Apparent coordination with other individuals to avoid identification or reporting thresholds
- Requests for cheques or payment instruments that are not related to gambling winnings
- Minimal gambling activity relative to the value or frequency of funds deposited
- Enquiries that suggest an intent to avoid reporting or identification obligations
- Presentation of forged, altered, or otherwise suspicious identification documents
- Multiple accounts identified as being controlled by the same individual under different or inconsistent identities
5. Reporting Obligations
5.1 Suspicious Transaction Reports
Where there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, a Suspicious Transaction Report (STR) is submitted to FINTRAC in accordance with the PCMLTFA and its regulations. Reasonable grounds to suspect do not require proof that an offence has occurred.
5.2 Large Cash Transaction Reports
A Large Cash Transaction Report (LCTR) is submitted to FINTRAC for any cash transaction of CAD 10,000 or more received from or on behalf of a customer in a single transaction, or in multiple cash transactions that together total CAD 10,000 or more within a 24-hour period.
5.3 Tipping Off Prohibition
Customers and third parties must not be informed that an STR has been filed or is being considered. Disclosure of this information to a subject of a report or to any other person in circumstances that could lead to such disclosure is prohibited under Canadian law.
6. Record Keeping
KYC documentation, transaction records, and other compliance-related records are retained for a minimum of five years from the date of the transaction or from the end of the customer relationship, whichever is later. Records are maintained in a manner that permits timely retrieval for regulatory examination or law enforcement purposes and in accordance with applicable legislative requirements.
7. Data Protection and Privacy
Personal data collected for AML and KYC purposes is processed on the basis of legal obligation under applicable legislation. Customers are informed of:
- The categories of personal data collected
- The purposes for which the data is used
- The circumstances in which data may be disclosed to regulatory authorities or law enforcement
AML and KYC data is not used for marketing purposes without a separate and valid legal basis. Subject to applicable AML record-keeping obligations and other legal restrictions, customers may have rights of access and correction in relation to their personal data. Where a legal obligation to retain data exists, any request for deletion is assessed in light of that obligation before action is taken.
8. Staff Training and Internal Compliance
Relevant staff receive AML and counter-terrorist financing training appropriate to their role. Training covers:
- Recognition of red flag indicators
- Customer identification and verification procedures
- Obligations relating to reporting and record keeping
- Legal and regulatory consequences of non-compliance
Training records are maintained and reviewed as part of the internal compliance process. An internal compliance review is conducted on a regular basis. Periodic external AML audits may also be conducted or commissioned to assess the effectiveness of the AML/CTF program and to identify required improvements.
9. Policy Review
This Policy is reviewed at least annually and updated as necessary to reflect changes in applicable legislation, regulations, FINTRAC guidance, or operational risk. The most current version of this Policy governs customer interactions and internal AML/KYC procedures at Cascades Casino Chatham.