1. Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Caesars Windsor. It describes the obligations that arise under Canadian federal law, the procedures used to verify customer identity, and the standards applied to monitor and report transactions.
The policy applies to all persons who access gaming services at Caesars Windsor, whether in person or through any account-based channel. It applies at all stages of the customer relationship, from initial registration through to account closure.
2. Legal Framework
Caesars Windsor operates in compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). This is the primary federal statute governing anti-money laundering and counter-terrorist financing obligations for Canadian casinos and gaming operators.
Oversight and reporting obligations under this framework are administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). FINTRAC publishes binding guidance for casino operators, including specific identity verification requirements and indicators of suspicious activity. Internal procedures are aligned with that guidance.
Where provincial requirements impose additional obligations, those requirements are incorporated into the operating procedures of the service.
3. Identity Verification Requirements
Identity verification is required in the following circumstances:
- Receipt of cash in the amount of 10,000 CAD or more in a single transaction
- Receipt of funds of 3,000 CAD or more, including by non-cash means
- Extension of credit of 3,000 CAD or more
- Foreign currency exchange transactions of 3,000 CAD or more
- Large virtual currency transactions as defined under FINTRAC guidance
- Casino disbursements as specified under applicable rules
- Any transaction that gives rise to a suspicion of money laundering or terrorist financing, regardless of the amount involved
Identity verification must be completed at the time of the transaction. For suspicious transactions, verification is required before a Suspicious Transaction Report is filed with FINTRAC.
4. Acceptable Identity Documents
To satisfy verification requirements, customers must present government-issued identification that confirms full legal name, date of birth, and photograph. Acceptable documents include:
- A valid passport
- A provincial or territorial driver’s licence
- Another government-issued photo identification document that meets applicable standards
Where verification is conducted for account-based access, additional documentation may be requested to confirm residential address or source of funds, depending on the risk profile of the account or transaction.
Expired documents are not accepted. Copies or photographs of documents are subject to internal authentication procedures before they are accepted as valid.
5. Customer Due Diligence
Beyond initial identity verification, ongoing customer due diligence is applied in proportion to the level of risk associated with each customer relationship.
5.1 Risk Assessment
Each customer is assigned a risk classification based on factors including transaction history, source of funds, geographic indicators, and the nature and frequency of gaming activity. Higher-risk classifications may result in enhanced due diligence measures.
5.2 Politically Exposed Persons and Sanctions Screening
Customers are screened against lists of politically exposed persons, sanctioned individuals and entities, and relevant adverse media sources. Screening is conducted at onboarding and on an ongoing basis. Where a match is identified, the account is subject to enhanced review before any transaction is processed.
5.3 Source of Funds
For transactions or account activity that exceed defined thresholds or that present elevated risk indicators, documentation confirming the legitimate source of funds may be requested. Failure to provide satisfactory documentation may result in the transaction being declined or the account being suspended pending review.
6. Transaction Monitoring
Transaction monitoring systems are maintained on a continuous basis. Monitoring is designed to detect patterns or activity that may indicate money laundering, terrorist financing, or other financial crime. This includes, but is not limited to:
- Structuring of transactions to avoid reporting thresholds
- Unusual frequency or volume of transactions relative to account history
- Activity inconsistent with the stated purpose of the account
Where monitoring identifies activity that meets the threshold for a Large Cash Transaction Report or a Suspicious Transaction Report, the company is required to file that report with FINTRAC within the timeframes prescribed by law. Customers are not notified when a report has been filed.
7. Record Retention
Records related to identity verification, transactions, and due diligence are retained for at least the minimum period required under the PCMLTFA and associated regulations. These records are maintained in a format that allows production to FINTRAC or other competent authorities upon lawful request.
8. Customer Obligations
Customers are required to provide accurate and complete information when requested. This includes identity documents, source of funds declarations, and any other information determined to be necessary to meet compliance obligations.
Providing false, misleading, or incomplete information is a breach of the conditions under which access to services is granted. The company reserves the right to suspend or close an account, decline a transaction, or report the matter to relevant authorities where there is reason to believe that information provided is inaccurate or that an account is being used in a manner inconsistent with this policy.
9. Refusal and Restriction of Service
The company reserves the right to refuse service, restrict account activity, or terminate an account where:
- A customer fails or refuses to complete identity verification
- Documentation provided does not meet verification standards
- Transaction monitoring identifies activity that cannot be satisfactorily explained
- A customer is identified on a sanctions list or as a politically exposed person subject to restrictions
- Such action is required by law or by direction from a competent authority
Decisions made under this section that arise from legal compliance obligations are not subject to appeal through the standard customer service process.
10. Policy Review
This policy is reviewed on a regular basis to ensure consistency with current FINTRAC guidance, applicable legislation, and internal risk assessments. Updates take effect from the date they are published. Continued use of the services following an update constitutes acceptance of the revised policy.
For compliance-related enquiries, customers may use the official contact channels listed on the Caesars Windsor website.