1. Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy of Grand Villa Casino Burnaby. It defines the obligations of the casino and its customers in relation to identity verification, transaction monitoring, suspicious activity reporting, and record retention. This policy applies to all persons who access or use services provided by Grand Villa Casino Burnaby, regardless of the channel through which those services are accessed.
The policy is established in accordance with Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Grand Villa Casino Burnaby operates as a reporting entity under the PCMLTFA and is subject to all obligations applicable to casinos under that legislation and associated regulations.
2. Legal Framework
Grand Villa Casino Burnaby complies with the following regulatory instruments and standards:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) as Canada’s primary federal AML statute
- FINTRAC guidance and indicators for casinos, including the published document “Money Laundering and Terrorist Financing Indicators - Casinos”
- Applicable provincial gaming legislation and standards issued by the relevant provincial gaming authority
- Recommendations of the Financial Action Task Force (FATF) as they apply to casino and betting operators
Where provincial requirements impose obligations beyond the federal minimum, Grand Villa Casino Burnaby applies the more stringent standard.
3. Customer Identification and Verification
3.1 Identity Verification Requirements
Grand Villa Casino Burnaby is required to verify the identity of customers in accordance with PCMLTFA obligations and FINTRAC guidance. Customers must provide valid, government-issued identification documents when requested. Acceptable documents include those that confirm full legal name, date of birth, and residential address.
Verification is conducted at the point of account creation or registration, prior to the commencement of regulated gaming activity, and at any subsequent point where Grand Villa Casino Burnaby determines that re-verification is necessary based on risk assessment or changes in customer circumstances.
3.2 Enhanced Due Diligence
For customers identified as presenting a higher level of risk, Grand Villa Casino Burnaby applies enhanced due diligence (EDD) procedures. EDD may include:
- Verification of source of funds
- Verification of source of wealth
- Review of financial records or supporting documentation
- Additional screening against sanctions lists, politically exposed persons (PEP) databases, and adverse media sources
High-risk indicators that may trigger EDD include, but are not limited to:
- High transaction volumes relative to a customer’s stated financial profile
- Activity patterns inconsistent with normal gaming behaviour
- Residence in, or funding originating from, jurisdictions identified as high risk by FATF
- Requests to transfer funds to third parties
3.3 Politically Exposed Persons
Customers identified as politically exposed persons, or as close associates or family members of a PEP, are subject to mandatory enhanced due diligence. Grand Villa Casino Burnaby screens customers against PEP databases as part of the onboarding process and on an ongoing basis.
4. Risk-Based Approach
Grand Villa Casino Burnaby applies a risk-based approach to AML and KYC compliance. Customers are assigned a risk classification (low, medium, or high) based on factors including:
- Transaction volume and frequency
- Betting behaviour
- Country of residence
- Funding methods
- Results of identity and screening checks
The level of monitoring, due diligence, and documentation applied to each customer is proportionate to the assigned risk classification. Risk classifications are reviewed periodically and updated when new information becomes available or when customer behaviour changes in a manner that affects the risk assessment.
5. Transaction Monitoring
Grand Villa Casino Burnaby monitors customer transactions on an ongoing basis to detect patterns or behaviours that may indicate money laundering, terrorist financing, or other financial crime. Monitoring systems are designed to identify the following, among other indicators:
- Large cash transactions that meet or approach reporting thresholds
- Multiple transactions structured to remain below reporting thresholds, whether conducted individually or in apparent coordination with other persons
- Significant deposits followed by minimal gaming activity and rapid withdrawal requests
- Frequent cycles of deposits and withdrawals with no clear gaming purpose
- Deposits made using payment method details that do not correspond to the customer’s verified identity
- Requests to transfer funds or winnings to third-party accounts or to accounts in high-risk jurisdictions
- Use of multiple accounts linked by common identifiers such as IP address, device, or bank account
These indicators are consistent with FINTRAC’s published guidance for casinos and with the indicators identified in FINTRAC’s bulletin on money laundering through online gambling sites, as analyzed under Canadian law.
6. Reporting Obligations
6.1 Suspicious Transaction Reports
Grand Villa Casino Burnaby is required to file Suspicious Transaction Reports (STRs) with FINTRAC where there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing. STRs are filed regardless of the transaction amount.
6.2 Large Cash Transaction Reports
Grand Villa Casino Burnaby files Large Cash Transaction Reports (LCTRs) with FINTRAC for cash transactions of CAD 10,000 or more received in a single transaction or in multiple transactions totaling CAD 10,000 or more within a 24-hour period where there are reasonable grounds to believe they are connected.
6.3 Other Reporting
Additional reports are filed as required under the PCMLTFA and FINTRAC regulations, including casino disbursement reports and, where applicable, reports related to the transfer of virtual currency.
7. Record Retention
Grand Villa Casino Burnaby retains records related to customer identification, verification, transactions, and compliance activities in accordance with the retention periods prescribed under the PCMLTFA and FINTRAC regulations. Records are maintained in a manner that allows them to be retrieved and provided to FINTRAC or other competent authorities upon lawful request.
8. Customer Obligations
Customers of Grand Villa Casino Burnaby are required to:
- Provide accurate, complete, and current identification information when requested
- Cooperate with identity verification and enhanced due diligence procedures
- Refrain from structuring transactions for the purpose of avoiding identification or reporting thresholds
- Refrain from using accounts registered in another person’s name or providing false or altered identification documents
- Notify Grand Villa Casino Burnaby of any material change in circumstances that may affect their risk profile or the accuracy of information previously provided
Failure to comply with these obligations may result in suspension or closure of the customer’s account, refusal of transactions, and reporting to FINTRAC or other relevant authorities.
9. Account Restrictions and Closures
Grand Villa Casino Burnaby may restrict, suspend, or close an account where:
- A customer fails to provide required identification or verification documents within a reasonable period
- There are reasonable grounds to suspect that an account is being used for money laundering, terrorist financing, or fraud
- A customer is identified on a sanctions list or as a prohibited person under applicable law
- Transaction patterns or account activity are inconsistent with the customer’s verified profile and no satisfactory explanation is provided
Where an account is closed or restricted under this policy, Grand Villa Casino Burnaby will act in accordance with applicable legal obligations regarding the handling and reporting of any associated funds.
10. Staff Training and Internal Controls
Grand Villa Casino Burnaby maintains an internal AML compliance program that includes regular staff training, documented procedures, and designated compliance responsibilities. Frontline staff are trained to recognize indicators published by FINTRAC and to escalate concerns through internal reporting channels. The compliance program is subject to periodic internal review and external audit to assess its effectiveness and to identify areas requiring improvement.
11. Data Protection
Personal data collected during the KYC and AML process is processed in accordance with applicable Canadian privacy legislation. Data is used solely for the purposes of identity verification, compliance with AML obligations, and related legal requirements. Grand Villa Casino Burnaby applies appropriate technical and organizational measures to protect customer data against unauthorized access, disclosure, or loss.
12. Policy Review
This policy is reviewed periodically to ensure continued alignment with PCMLTFA requirements, FINTRAC guidance, provincial gaming regulations, and applicable FATF standards. Updates to this policy take effect upon publication. Customers are responsible for reviewing the current version of this policy as published by Grand Villa Casino Burnaby.