1. Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Cascades Casino North Bay. The policy establishes procedures and obligations governing customer identification, risk assessment, transaction monitoring, and reporting in accordance with applicable Canadian federal and provincial requirements.
Cascades Casino North Bay operates as a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and is subject to the supervisory authority of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). All persons accessing services at Cascades Casino North Bay are subject to the requirements described in this policy.
2. Legal Framework
The AML and KYC obligations of Cascades Casino North Bay are governed by the following:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
- FINTRAC guidance, including the directive titled “When to verify the identity of persons and entities - Casinos”
- Applicable provincial gaming regulations and licensing standards
Where provincial requirements impose additional obligations, those requirements apply alongside federal obligations. In the event of conflict, the more stringent requirement prevails.
3. Customer Identification and Verification
3.1 When Verification Is Required
Cascades Casino North Bay is required to verify the identity of a person or entity in the following circumstances:
Trigger event - Threshold
Large cash transaction - As defined by FINTRAC
Large virtual currency transaction - As defined by FINTRAC
Casino disbursement - Any amount
Extension of credit - CAD 3,000 or more
Receipt of funds - CAD 3,000 or more
Foreign currency exchange - CAD 3,000 or more
Suspicious transaction - Any amount
Identity verification is not required when funds of CAD 3,000 or more are received from a financial entity or public body, or from a person acting on behalf of such an entity, as specified in FINTRAC guidance.
3.2 Information and Documents Collected
To complete identity verification, Cascades Casino North Bay collects and records the following information:
- Full legal name
- Date of birth
- Residential address
- Type of government-issued photo identification document (for example, driver’s licence or passport)
- Unique identifying number of the document
- Issuing jurisdiction and country
- Document expiry date, where applicable
- Date on which verification was performed
Cascades Casino North Bay confirms that the document presented is authentic, valid, and current, and that the name and photograph correspond to the individual presenting the document. This applies whether the individual is present in person or verification is conducted remotely.
3.3 Acceptable Verification Methods
Verification may be conducted using one or more of the following methods, selected in accordance with a risk-based approach:
- Government-issued photo identification
- Credit file checks
- Dual-process methods using two independent and reliable sources
- Affiliate or third-party electronic identity verification services
- Biometric checks, where applicable
4. Source of Funds and Source of Wealth
Cascades Casino North Bay may require confirmation that funds used for gambling activity were obtained through lawful means. This is referred to as Source of Funds verification.
Documents accepted as evidence of source of funds include, but are not limited to:
- Bank statements
- Credit card statements
- Tax returns or notices of assessment
- Government-issued pay statements
- Documentation evidencing the origin of a gift or inheritance
For customers classified as high-risk, including high-value players, Cascades Casino North Bay may additionally require Source of Wealth documentation explaining the overall accumulation of the individual’s financial assets. Where satisfactory documentation cannot be provided, account activity may be suspended pending resolution.
5. Risk-Based Customer Due Diligence
5.1 Customer Risk Classification
Cascades Casino North Bay applies a risk-based approach to customer due diligence. Each customer is assigned a risk classification based on factors including:
- Transaction volume and frequency
- Geographic origin of funds
- Nature of gambling activity
- Behavioural indicators
- Adverse media or sanctions screening results
Risk classifications are reviewed periodically and updated when material changes in customer behaviour or circumstances are identified.
5.2 Standard Customer Due Diligence
Standard Customer Due Diligence (CDD) applies to all customers and includes identity verification, confirmation of source of funds where required by law or internal procedures, and ongoing monitoring of account activity.
5.3 Enhanced Due Diligence
Enhanced Due Diligence (EDD) applies to customers classified as high-risk. EDD measures include more frequent review of account activity, additional documentation requirements, Source of Wealth confirmation, and escalation to the compliance function for approval before continued service is provided.
6. Transaction Monitoring and Suspicious Activity
Cascades Casino North Bay maintains ongoing monitoring of customer transactions and account behaviour. The following patterns are treated as indicators requiring further review or escalation:
- Large deposits accompanied by minimal gambling activity
- Rapid or repeated withdrawals following deposits
- Frequent cycles of deposits and withdrawals without apparent gambling purpose
- Transactions structured to remain below reporting thresholds
- Multiple transactions conducted within a short period by the same individual or associated individuals
- Reluctance or refusal to provide required identification or documentation
- Inconsistent or implausible explanations for transaction activity
- Nervous, evasive, or defensive behaviour during identity or compliance checks
Where a suspicious transaction is identified, Cascades Casino North Bay files a Suspicious Transaction Report with FINTRAC in accordance with applicable requirements. Account activity may be restricted or suspended during the review period.
7. Record Keeping
Cascades Casino North Bay retains all records related to customer identification, due diligence, and transactions for a minimum period consistent with FINTRAC requirements. Records are maintained in a manner that allows retrieval for regulatory review or audit purposes.
8. Age Verification
No individual below the legal gambling age is permitted to access services at Cascades Casino North Bay. The minimum age requirement is determined by applicable provincial law. Age verification is conducted as part of the customer identification process and is a prerequisite to any account access or gambling activity.
9. Responsible Gambling Integration
AML and KYC controls at Cascades Casino North Bay are implemented in conjunction with responsible gambling obligations. Monitoring systems used for AML purposes also support the identification of potentially harmful gambling behaviour. Self-exclusion records and player behaviour data are incorporated into the overall compliance framework where relevant.
10. Compliance Governance
Cascades Casino North Bay maintains an internal compliance program that includes designated compliance personnel, staff training on AML and KYC obligations, documented policies and procedures, and periodic internal review. The compliance program is subject to review and update to reflect changes in applicable law, FINTRAC guidance, or regulatory standards.
11. Contact for Compliance Inquiries
Inquiries related to this policy or to identity verification requirements may be directed to the compliance function of Cascades Casino North Bay through the contact channels available at the property or on the official website.