AML/KYC Policy
1. Introduction
This policy outlines the Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements governing Starlight Casino locations operated by Gateway Casinos & Entertainment Limited in Canada. All facilities are subject to federal and provincial regulations related to financial crime prevention, customer identification, and transaction monitoring. The policy applies to all gaming and non-gaming services at properties in British Columbia, Alberta, and Ontario.
2. Regulatory Framework
2.1. Federal Compliance
Starlight Casino operates under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), overseen by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Compliance systems are maintained to detect, prevent, and report suspicious financial activity in accordance with federal law.
2.2. Provincial Oversight
Operations are regulated by the following provincial gaming authorities:
– British Columbia: British Columbia Lottery Corporation (BCLC)
– Alberta: Alberta Gaming, Liquor & Cannabis Commission (AGLC)
– Ontario: Ontario Lottery and Gaming Corporation (OLG)
All rules, standards, and operational requirements set by these bodies are observed.
3. Customer Identification Requirements
3.1. Mandatory Verification Circumstances
Identity verification is required in these situations:
– Cash transactions totaling $10,000 or more within a 24-hour period
– Casino disbursements of $10,000 or more
– Extension of credit of $3,000 or more
– Receipt of funds of $3,000 or more
– Foreign currency exchange of $3,000 or more
– Any transaction deemed suspicious, regardless of amount
– Enrollment in customer reward programs (Encore Rewards, My Club Rewards)
3.2. Acceptable Identification Documents
Valid government-issued photo identification is required, such as:
– Passport
– Driver’s license
– Provincial or territorial identification card
– Permanent resident card
3.3. Information Collected
The following information is collected and recorded:
– Full legal name
– Date of birth
– Residential address
– Telephone number
– Email address (if applicable)
– Occupation or nature of principal business
– Government-issued identification number and issuing jurisdiction
4. Source of Wealth and Funds Verification
4.1. Enhanced Due Diligence
For transactions exceeding certain thresholds or risk indicators, supporting documentation regarding the source of wealth or funds may be required. Acceptable documents include:
– Employment records or payslips
– Bank statements
– Tax records or assessments
– Business ownership or asset documentation
– Investment account statements
4.2. Customer Obligation
Customers must provide requested documentation within a reasonable period. Failure to comply may result in restriction or denial of gaming services.
5. Transaction Monitoring and Reporting
5.1. Ongoing Monitoring
Transaction monitoring systems are in place to identify patterns indicative of money laundering, terrorist financing, or other financial crimes. Monitoring includes:
– Analysis of transaction frequency, volume, and patterns
– Assessment of consistency between customer activity and stated occupation or source of income
– Detection of structuring intended to avoid reporting thresholds
– Identification of unusual cash handling or currency exchange activity
5.2. Suspicious Transaction Reporting
Suspicious transactions are reported to FINTRAC and relevant provincial gaming regulators. A transaction may be considered suspicious due to:
– Inconsistency with the customer profile or legitimate entertainment activity
– Involvement of multiple individuals coordinating transactions
– Use of third-party facilitators for cash handling or exchange
– Attempting to evade identification or reporting processes
– Patterns suggesting proceeds of crime or organized criminal activity
5.3. Large Cash Transaction Reporting
All cash transactions of $10,000 or more are subject to reporting to FINTRAC as mandated by federal requirements. The 24-hour rule applies to aggregate transactions by or on behalf of a single individual.
6. Record Retention
Records of customer identification, transaction details, and compliance documentation are retained for a minimum of five years from the date of the last transaction or account closure, in accordance with FINTRAC and provincial requirements.
7. Privacy and Information Disclosure
7.1. Gaming-Related Information
Information collected for gaming-related purposes, including identity verification and transaction records, is governed by public sector privacy legislation administered by provincial gaming authorities. Such information may be disclosed to:
– Provincial gaming regulators (BCLC, AGLC, OLG)
– FINTRAC
– Law enforcement agencies on lawful request
– Companies within the Gateway Casinos & Entertainment Limited corporate structure
7.2. Non-Gaming Information
Personal data collected for non-gaming services (restaurants, entertainment, hospitality) is managed under private sector privacy legislation, with specific use and disclosure restrictions.
7.3. Customer Consent
By providing identification and participating in gaming activities, customers consent to collection, use, and disclosure of personal information as outlined in this policy and as required by law.
8. Refusal of Service
Service may be refused or access restricted in the following circumstances:
– Failure to provide required identification or supporting documentation
– Providing false or misleading information
– Engagement in suspicious or potentially illegal behaviour
– Presence on self-exclusion or trespass lists
– Non-compliance with this policy or applicable regulations
9. Self-Exclusion and Trespass
Individuals who are self-excluded or trespassed from any Starlight Casino or facilities operated by provincial authorities are not permitted to access properties. Identification systems, including facial recognition technology, may be used to enforce exclusion.
10. Compliance Officer
The Deputy General Counsel and Privacy Officer at Gateway Casinos & Entertainment Limited is responsible for AML/KYC compliance oversight. Questions or concerns about this policy should be directed to the compliance department.
11. Policy Updates
This policy may be amended to reflect changes in federal or provincial law, regulatory guidance, or operational requirements. Customers are responsible for reviewing current policy provisions relevant to their activities.
12. Contact Information
For AML/KYC inquiries or to provide required documentation:
Starlight Casino New Westminster: 350 Gifford Street, New Westminster, BC
Starlight Casino Edmonton: (780) 444-2112
Starlight Casino Point Edward: 2000 Venetian Boulevard, Point Edward, ON
This policy applies to all Starlight Casino locations and supersedes previous versions.