- Overview
Club Regent Casino operates in compliance with Canadian federal and applicable provincial anti-money laundering and know-your-customer requirements. This document describes the obligations that apply to the casino and to its customers under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the regulations enforced by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
As a reporting entity under PCMLTFA, Club Regent Casino maintains a written compliance program that includes policies and procedures, a designated compliance officer, ongoing staff training, customer risk assessment, transaction monitoring, and mandatory reporting to FINTRAC where required by law.
- Legal Framework
The primary legal basis for this policy is the federal PCMLTFA and its associated regulations. FINTRAC issues sector-specific guidance for casinos that defines when identity verification is required, which records must be kept, and which transactions must be reported. Where provincial gaming regulations impose additional or complementary AML requirements, those requirements are applied alongside the federal framework.
- When Identity Verification Is Required
Club Regent Casino is required to verify the identity of a person or entity in connection with the following activities and transactions:
Activity or Transaction - Threshold
- Receipt of cash in a single transaction - CAD 10,000 or more
- Casino disbursement - CAD 10,000 or more
- Extension of credit - CAD 3,000 or more
- Receipt of funds for certain activities - CAD 3,000 or more
- Account opening (online platform) - At account creation, regardless of amount
- Suspicious transaction - Any amount, where suspicion arises
These thresholds reflect FINTRAC guidance applicable to casinos. Where a transaction is structured or appears to be structured to avoid a threshold, verification obligations still apply and the transaction may be reported as suspicious.
- Accepted Methods of Identity Verification
FINTRAC prescribes the following methods for verifying the identity of natural persons. Club Regent Casino applies one or more of these methods depending on the context and the information available.
4.1 Government-Issued Photo Identification
The document must be authentic, valid, and current. It must be issued by a federal, provincial, territorial, or foreign government equivalent, bear the person’s full legal name and photograph, and carry a unique identifying number. Expired documents are not accepted.
4.2 Credit File Method
Identity may be verified using a Canadian credit bureau file that is at least three years old, contains at least two active trade lines, and matches the person’s name, address, and date of birth. The check must be performed in real time at the point of verification.
4.3 Dual-Process Method
Two pieces of information from two independent and reliable sources must confirm any two of the following combinations: name and date of birth; name and address; or name and financial account number. Acceptable sources include government bodies, Crown corporations, financial institutions, and utility providers. Social media profiles and non-independent sources are not acceptable under this method.
4.4 Affiliate or Reliance Method
Where permitted by FINTRAC guidance, Club Regent Casino may rely on identity verification already performed by an affiliate or a third party that has carried out compliant KYC procedures, provided that the required records are accessible and the relying arrangement meets regulatory conditions.
- Customer Due Diligence
Club Regent Casino applies a risk-based approach to customer due diligence. All customers are subject to standard due diligence at the applicable trigger points described in Section 3. Customers assessed as higher risk are subject to enhanced due diligence, which may include additional identity checks, source-of-funds documentation, and more frequent monitoring of account activity.
Higher-risk indicators include, but are not limited to:
- The customer is identified as a politically exposed person (PEP) or a close associate of a PEP
- The customer’s transactions involve jurisdictions identified as high-risk by FINTRAC or international bodies
- The customer’s activity shows patterns inconsistent with their stated profile or source of funds
- The customer requests transactions that have no apparent lawful purpose
Where enhanced due diligence cannot be completed to a satisfactory standard, Club Regent Casino may restrict, suspend, or close the account and report the matter to FINTRAC as required.
- Source of Funds
For large cash buy-ins and high-value gaming activity, Club Regent Casino may require a customer to complete a source-of-funds declaration. In British Columbia, any person making buy-ins with cash, bank drafts, or certified cheques of CAD 10,000 or more in a 24-hour period is required to complete such a declaration. Identity verification is required for buy-ins of CAD 3,000 or more in a single day in that province.
Where a customer is unable or unwilling to provide satisfactory source-of-funds information, the casino may decline to process the transaction and may file a suspicious transaction report with FINTRAC.
- Transaction Monitoring and Reporting
Club Regent Casino monitors customer transactions and account activity on an ongoing basis. The following reports are filed with FINTRAC as required by law:
- Large Cash Transaction Report: filed when CAD 10,000 or more in cash is received in a single transaction
- Casino Disbursement Report: filed when a disbursement of CAD 10,000 or more is made, including identification of the ultimate beneficiary
- Suspicious Transaction Report: filed when there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing, regardless of the amount
- Terrorist Property Report: filed immediately upon knowledge or reasonable grounds to believe that property is owned or controlled by a terrorist or terrorist group
Monitoring covers cashless systems and player accounts as well as cash transactions. Indicators reviewed include transfers between player accounts without associated gameplay, rapid opening and closing of accounts, aggregate transaction patterns that exceed prescribed thresholds, and unusual deposit or withdrawal activity.
- Restrictions on Virtual Currency
Unless specifically authorized by the applicable provincial regulator and compliant with PCMLTFA and FINTRAC guidance, Club Regent Casino does not permit the use of virtual currency, cryptocurrency, or non-fiat value mechanisms in connection with gaming accounts or cashless operations. Transactions must be conducted in Canadian dollars or other fiat currency as permitted under applicable rules.
- Record Retention
Club Regent Casino retains all records required under PCMLTFA and its regulations for a minimum of five years from the date the record was created or the transaction was completed. Records are maintained in a manner that allows them to be produced to FINTRAC or the applicable provincial regulator upon request.
- Staff Training and Compliance Officer
All staff members who are exposed to potential money laundering or terrorist financing risk receive mandatory AML training. In Alberta, AML certification is required for all such individuals in accordance with AGLC requirements. Club Regent Casino has designated a compliance officer responsible for overseeing the implementation and ongoing effectiveness of this policy, coordinating with FINTRAC and provincial regulators, and ensuring that the program is updated to reflect changes in legislation, guidance, and regulatory expectations.
- Policy Updates
This policy is reviewed and updated on a regular basis to reflect amendments to PCMLTFA, new FINTRAC guidance, provincial regulatory bulletins, and changes in the risk environment applicable to casino and betting operations in Canada. Customers are subject to the version of this policy in effect at the time of their account activity or transaction.