Casino Playground AML / KYC Policy for Canadian Users

Description (D): Casino Playground AML and KYC Policy for Canada describing identity verification, transaction monitoring, and reporting obligations under applicable anti-money laundering legislation.

H1: Casino Playground AML / KYC Policy

At Casino Playground, operations are subject to Canadian anti-money laundering and counter-terrorist financing legislation. This policy describes obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the role of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as the federal supervisory authority, and the requirements that apply to users and to the platform as a casino operator.

This policy applies to all accounts registered with Casino Playground. It governs the collection, verification, and use of identity information, the monitoring of transactions, and the circumstances in which reports must be filed with regulatory authorities.

1. Legal Framework

AML and KYC obligations for Casino Playground are grounded in the PCMLTFA and related regulations. FINTRAC, as Canada’s financial intelligence unit, is the federal authority responsible for supervising compliance among casino operators. The company is required to maintain a compliance program that includes written policies and procedures, risk assessment, training, and an independent review function.

Where provincial frameworks impose additional requirements, including but not limited to those administered by the British Columbia Lottery Corporation (BCLC) in British Columbia or by iGaming Ontario, the stricter standard is applied where multiple frameworks are relevant to a given transaction or account.

2. Know Your Customer (KYC) - Identity Verification

2.1 When Verification Is Required

Identity verification is required before a user can deposit funds, request a withdrawal, or participate in any real-money activity. Verification is also required in the following circumstances:

When CAD 10,000 or more in cash is received in a single transaction
When a credit extension of CAD 3,000 or more is involved
When funds of CAD 3,000 or more are received
When a foreign currency exchange of CAD 3,000 or more takes place
When a large virtual currency transaction occurs
When a casino disbursement is made
When a transaction is flagged as suspicious, regardless of the amount involved

For suspicious transactions, identity verification must be completed before a Suspicious Transaction Report (STR) is filed with FINTRAC.

2.2 Acceptable Identity Documents

To complete identity verification, documents from the following categories may be requested:

Government-issued photo identification: passport, driver’s licence, provincial identification card
Proof of address: utility bill, bank statement, or government correspondence dated within the last 90 days
Proof of payment method ownership: bank statement, screenshot of an e-wallet account, or card statement

All documents must be current, clearly legible, and issued by a recognized authority. The company reserves the right to request additional documentation if the initial submission does not meet verification standards.

2.3 Verification Process

Once the required documents are submitted, the compliance function reviews the information provided. Automated identity verification tools may be used as part of this process. If documents are incomplete, expired, illegible, or inconsistent with the information on the account, the user may be contacted to provide corrected or supplementary materials. Account access may be restricted during the verification period.

Altered, forged, or third-party documents are not accepted. Submission of false identification is grounds for immediate account closure and may be reported to the relevant authorities.

3. Source of Funds

In addition to identity verification, users may be required to demonstrate the legitimate origin of funds used for gambling activity. A source-of-funds declaration or supporting documentation may be requested in particular when:

A user deposits or accumulates funds that appear disproportionate to the stated financial profile
A user’s transaction pattern is inconsistent with normal activity for that account
A cash equivalent instrument (such as a bank draft or certified cheque) of CAD 10,000 or more is presented within a 24-hour period

Acceptable source-of-funds documentation may include recent payslips, tax returns, bank statements, or documentation relating to a business transaction, inheritance, or asset sale. Each case is assessed individually, and additional materials may be requested at the discretion of the company.

4. Transaction Monitoring and Reporting

Casino Playground maintains ongoing transaction monitoring for all accounts. Monitoring systems are designed to identify patterns that may indicate money laundering, terrorist financing, or other forms of financial crime.

The following reports must be filed with FINTRAC where applicable legal thresholds and criteria are met:

Suspicious transaction reports, regardless of the amount involved
Large cash transaction reports for cash transactions of CAD 10,000 or more
Large virtual currency transaction reports for virtual currency transactions of CAD 10,000 or more
Casino disbursement reports for disbursements exceeding CAD 10,000, including the identity of the ultimate beneficiary

Reports are filed in accordance with FINTRAC timelines and technical requirements. Users are not notified when a report has been filed, as disclosure of such reports is prohibited under Canadian law.

5. PEP, Sanctions, and Adverse Media Screening

As part of the compliance program, all accounts are screened against:

Politically exposed persons (PEP) lists
Sanctions lists maintained by Canadian and relevant international authorities
Adverse media sources that relate to financial crime

Where a user is identified as a PEP or appears on a sanctions list, enhanced due diligence measures apply. These measures may include additional documentation requirements, senior management approval for certain account activities, and more frequent review of transaction history.

6. AML Red Flags

The following behaviours and indicators may trigger additional review, account restriction, or the filing of a report with FINTRAC:

Use of multiple accounts under different identities
Payment details that do not match the registered account holder
Large deposits followed by minimal or no gameplay and an immediate withdrawal request
Apparent inconsistency between stated financial standing and actual transaction volumes
Attempts to structure transactions to remain below reporting thresholds
Submission of false, altered, or misleading identification documents

This list is not exhaustive. A risk-based approach is applied, and any account activity that appears inconsistent with expected behaviour may be investigated.

7. Recordkeeping

Identity verification records, transaction records, and compliance documentation are retained for at least the minimum period required by the PCMLTFA and applicable regulations. Records are stored securely and are made available to FINTRAC or other competent authorities upon lawful request.

8. Player Obligations

By registering and maintaining an account with Casino Playground, users agree to:

Provide accurate and complete identity information at registration and upon request
Submit valid documentation within the timeframe specified in any verification request
Notify the platform promptly of any changes to personal information, including name, address, or source of funds
Refrain from using the account for any purpose that constitutes money laundering, terrorist financing, or fraud

Failure to comply with these obligations may result in account suspension or termination, withholding of funds pending investigation, or referral to law enforcement or regulatory authorities.

9. Contact and Compliance Inquiries

Questions about this policy or about a specific verification request should be directed to the compliance team through the official support channels listed on the Casino Playground website. The status of any regulatory report or investigation cannot be discussed.

This policy is reviewed periodically and updated to reflect changes in applicable law, regulatory guidance, or internal risk assessment. The version published on the Casino Playground website is the current operative version.