1. Introduction
This document sets out the anti-money laundering (AML) and know-your-customer (KYC) policy applicable to Vegas Casino operations serving customers in Canada. The policy is designed to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and regulations issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Vegas Casino is classified as a reporting entity under Canadian federal law and maintains procedures to verify customer identity, monitor transactions, and report suspicious activity in accordance with regulatory requirements.
2. Regulatory Framework
For AML purposes, Vegas Casino operates under the supervision of FINTRAC. Core obligations include customer identification, record-keeping, transaction reporting, and the maintenance of a written compliance program. The company also complies with applicable provincial gaming regulations in jurisdictions where it is licensed to offer casino services. This policy reflects the specific identity verification triggers, transaction thresholds, and reporting duties prescribed by FINTRAC guidance for casinos.
3. When Identity Is Verified
Identity verification is required for every person or entity in the following circumstances:
3.1. Large Cash Transactions
When cash in the amount of CAD 10,000 or more is received in a single transaction, identity must be verified before or at the time of the transaction.
3.2. Large Virtual Currency Transactions
When virtual currency valued at CAD 10,000 or more is received in a single transaction, identity must be verified.
3.3. Suspicious Transactions
If there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing, identity must be verified regardless of the transaction amount and a suspicious transaction report must be filed with FINTRAC.
3.4. Casino Disbursements
When CAD 10,000 or more is disbursed in a single transaction for which a Casino Disbursement Report is required, identity must be verified.
3.5. Extension of Credit
When credit of CAD 3,000 or more is extended to a customer, identity must be verified at or before the time credit is extended.
3.6. Receipt of Funds
When CAD 3,000 or more in funds is received from a customer (other than cash, which is subject to the CAD 10,000 threshold), identity must be verified.
3.7. Foreign Currency Exchange
When a foreign currency exchange transaction of CAD 3,000 or more is conducted, identity must be verified.
3.8. Electronic Funds Transfers
Identity must be verified when an electronic funds transfer of CAD 1,000 or more is initiated on a customer’s behalf, or when the final leg of an international electronic funds transfer of CAD 1,000 or more is received for a customer.
3.9. Account Opening
Identity is verified for all account holders and persons authorized to give instructions on accounts opened with Vegas Casino, subject to defined regulatory exceptions.
4. Exceptions to Verification
Identity is not verified in the following cases, as permitted by FINTRAC regulations:
- When large cash or virtual currency transactions are received from financial entities or public bodies.
- When funds are deposited into business accounts under specific conditions set out in the regulations.
- When identity has previously been verified using methods acceptable under the regulations, records are current, and there is no doubt about the information on file.
5. Methods of Identity Verification
Identity is verified using government-issued photo identification and other reliable, independent source documents as prescribed by FINTRAC. For individuals, the following information is collected and verified:
- Full name
- Date of birth
- Address
- Occupation or nature of principal business
For entities, the following information is collected and verified:
- Entity name
- Address
- Nature of principal business
- Names of directors or persons who own or control 25 percent or more of the entity, as required
For remote or online verification, digital identity verification tools that meet regulatory standards are used, including document authentication, biometric checks, and cross-reference with authoritative data sources.
6. Ongoing Monitoring and Record Updates
Client identification information must be kept up to date, including name, address, and occupation or principal business. Periodic reviews of customer information are conducted, and updated documentation may be requested to ensure records remain accurate and current. Customers are required to notify Vegas Casino promptly of any changes to personal or business information.
7. Transaction Monitoring and Reporting
All transactions are monitored for patterns or activities that may indicate money laundering, terrorist financing, or other financial crimes. Systems are used to flag transactions that meet regulatory reporting thresholds or exhibit suspicious characteristics. The following reports are filed with FINTRAC as required:
- Large Cash Transaction Reports (for cash receipts of CAD 10,000 or more)
- Large Virtual Currency Transaction Reports (for virtual currency receipts of CAD 10,000 or more)
- Casino Disbursement Reports (for disbursements of CAD 10,000 or more)
- Suspicious Transaction Reports (for any transaction, regardless of amount, where there are reasonable grounds to suspect money laundering or terrorist financing)
- Electronic Funds Transfer Reports (for international EFTs of CAD 10,000 or more)
8. Compliance Program
Vegas Casino maintains a written AML compliance program that includes:
- Appointment of a designated compliance officer responsible for AML policy implementation and oversight
- Risk assessment procedures to identify and evaluate money laundering and terrorist financing risks associated with operations, customers, and products
- Internal policies and procedures covering customer due diligence, transaction monitoring, record-keeping, and reporting
- Ongoing training for all staff exposed to money laundering or terrorist financing risks
- Independent effectiveness testing of the AML program on a regular basis
9. Record-Keeping
Identity verification records, transaction records, and reports are retained for a minimum of five years from the date of the last transaction or the date a business relationship ends, as required by law. Records are kept in a format that allows for timely retrieval and production to FINTRAC or law enforcement upon lawful request.
10. Customer Obligations
Customers are required to provide accurate and complete information when requested for identity verification or account updates. Failure to provide required documentation or information may result in restrictions on an account, suspension of transactions, or closure of an account. Customers must not use Vegas Casino services to engage in money laundering, terrorist financing, or any other illegal activity.
11. Enhanced Due Diligence
Enhanced due diligence measures are applied to customers or transactions that present higher risk, including:
- Politically exposed persons (PEPs), heads of international organizations, and their family members or close associates
- Customers from high-risk jurisdictions identified by FINTRAC or international bodies
- Transactions involving large amounts, unusual patterns, or lack of apparent economic purpose
Enhanced measures may include additional identity verification, inquiries regarding source of funds or wealth, senior management approval, and more frequent monitoring.
12. Sanctions Screening
All customers and transactions are screened against Canadian and international sanctions lists, including those maintained by the United Nations, the Office of the Superintendent of Financial Institutions (OSFI), and other relevant authorities. Accounts are not opened for, and transactions are not conducted with, individuals or entities on sanctions lists.
13. Cooperation with Authorities
Vegas Casino cooperates with FINTRAC, law enforcement, and other regulatory authorities. Lawful requests for information are answered, and assistance is provided in investigations related to money laundering, terrorist financing, and other financial crimes. Customers are not informed that a suspicious transaction report has been filed or that an investigation is underway, as prohibited by law.
14. Policy Updates
This policy is reviewed and updated periodically to reflect changes in Canadian AML legislation, FINTRAC guidance, and the internal risk assessment. Material changes to this policy are communicated through the website or direct notification to account holders. Continued use of the services after policy updates constitutes acceptance of the revised terms.
15. Contact Information
For questions or concerns regarding this AML / KYC policy, or to provide updated identification or account information, customers should contact the compliance department through the support channels listed on the Vegas Casino website.