AML/KYC Policy
1. Introduction and Scope
This policy outlines the anti-money laundering (AML) and know-your-customer (KYC) requirements for all Cascades Casino properties operated by Gateway Casinos & Entertainment Limited in Canada. The document applies to operations in British Columbia and Ontario and reflects compliance with applicable federal AML laws, regulations enforced by FINTRAC, provincial gambling regulations, and service agreements with provincial Crown corporations such as BCLC and OLG.
2. Regulatory Framework
2.1 Federal Obligations
Cascades Casino is designated as a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Legal obligations include implementing customer identification procedures, recordkeeping, reporting to FINTRAC on suspicious and large cash transactions, and maintaining a compliance program. The compliance program comprises a designated compliance officer, written internal policies, risk assessments, and regular staff training.
2.2 Provincial Requirements
In British Columbia, operational service agreements with BCLC require adherence to specified operational policies and AML measures. In Ontario, the Alcohol and Gaming Commission of Ontario (AGCO) and OLG provide regulatory oversight. Operations are carried out in accordance with all provincial regulations and AML directives.
3. Customer Identification and Verification
3.1 Entry Requirements
Patrons must meet the legal gambling age in the relevant province (19 years in British Columbia and Ontario). Valid government-issued photo identification must be presented at entry or upon staff request. Failure to provide acceptable identification may result in refusal of entry.
3.2 Players Card Issuance
Prior to the issuance of a Players Card, government-issued photo identification is verified. Required information includes full legal name, date of birth, residential address, and details from the identification document. Copies or records of identification documents are retained as mandated by law.
3.3 Transaction-Based Identification
Further identification and verification procedures apply for transactions meeting or exceeding prescribed thresholds. These include significant cash buy-ins, chip redemptions, cheque issuance, or as required under federal and provincial regulations.
4. Transaction Monitoring and Reporting
4.1 Large Cash Transactions
All large cash transactions are recorded and reported as required by FINTRAC. Staff receive training to recognize reportable transactions and to complete required documentation in a timely and accurate manner.
4.2 Suspicious Transactions
Ongoing monitoring is conducted for signs of money laundering or terrorist financing. Indicators include, but are not limited to, minimal play coupled with significant cash-out, structuring to circumvent reporting thresholds, discrepancies in patron information, use of multiple identities, and activities inconsistent with a given financial profile. Suspicious transactions are reported to FINTRAC and relevant provincial regulators within prescribed timelines.
4.3 Prohibited Practices
Exchanging small-denomination bills for larger denominations is not facilitated except where directly related to gaming activity in limited scenarios. Cheques are issued solely for gaming-related winnings or as otherwise allowed under provincial operational policies.
5. High-Value Patrons
Patrons frequently engaging in high-value or large-cash transactions are subject to enhanced due diligence. Additional information regarding source of funds, occupation, and transaction purpose may be requested. The provision of complimentary amenities to such patrons does not alter the application of AML obligations, and all high-value patrons are subject to full identification, monitoring, and reporting requirements.
6. Record Keeping
Records are maintained in accordance with legal requirements concerning customer identification, transaction information, and reports submitted to FINTRAC and provincial regulators. Storage is secure and access is limited to authorized personnel. Full cooperation is afforded to regulatory audits, law enforcement inquiries, and third-party reviews.
7. Staff Training and Compliance
Mandatory training is provided to employees covering AML and KYC requirements, identification and verification procedures, recognition of suspicious activity, documentation protocols, and escalation procedures. Training is provided at the time of hiring and updated regularly to reflect regulatory changes and emerging risks.
8. Privacy and Data Protection
Personal information collected for AML and KYC purposes is managed in accordance with applicable federal and provincial privacy legislation. Collection, use, and disclosure are restricted to purposes required to satisfy legal and regulatory obligations. Patrons may request access to their personal data or direct privacy-related inquiries to the designated privacy officer.
9. Self-Exclusion and Barring
Self-exclusion programs implemented by provincial regulators are enforced. Patrons who have entered self-exclusion or have been barred are denied entry and gaming services. Enforcement is supported through robust identification at entry and gaming activity points.
10. Cooperation with Authorities
Cascades Casino operations cooperate fully with FINTRAC, provincial regulators, the Gaming Policy and Enforcement Branch (GPEB) in British Columbia, AGCO in Ontario, and law enforcement. Responses to information requests and access to records or staff are provided as required by law.
11. Refusal of Service
Service, transactions, or access to gaming facilities may be refused or restricted for individuals who do not fulfill identification requirements, provide false or misleading information, engage in suspicious activities, or otherwise pose AML or regulatory risks. Such measures are undertaken in compliance with internal policy and regulatory obligations.
12. Policy Updates
This policy is reviewed periodically and updated to reflect changes in federal or provincial legislation, regulatory guidance, or operational procedures. Significant amendments are communicated to staff through updated training and internal announcements.
13. Contact Information
Inquiries concerning this policy should be directed to the compliance department or the management office of the relevant Cascades Casino property. Contact details are available on property websites and at casino reception desks.