- Introduction and Purpose
This document sets out the Anti-Money Laundering and Know Your Customer Policy (AML / KYC Policy) of Pure Casino Yellowhead. It defines the obligations, procedures, and controls maintained to comply with applicable Canadian legislation and regulatory requirements governing the prevention of money laundering and terrorist financing in the casino and betting sector.
Pure Casino Yellowhead operates as a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations. Oversight and enforcement of these obligations are conducted by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This Policy applies to all players, accounts, and transactions processed through Pure Casino Yellowhead.
- Legal Framework
Pure Casino Yellowhead’s AML / KYC obligations arise from the following regulatory sources:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations
- FINTRAC sector-specific guidance and red-flag indicators for casinos
- Applicable provincial gambling licensing requirements
Where provincial requirements impose additional obligations beyond the federal framework, the more stringent standard is applied.
- Risk-Based Approach
Pure Casino Yellowhead applies a risk-based approach to AML and KYC compliance. The level of scrutiny applied to a player, account, or transaction is proportionate to the assessed risk of money laundering or terrorist financing associated with that player or activity.
Risk assessment considers, in particular:
- Customer type, including domestic versus foreign players, high-volume players, and politically exposed persons (PEPs)
- Products and services accessed
- Delivery channels, including online and in-person access
- Geographic exposure and cross-border activity
Players or transactions assessed as higher risk are subject to enhanced due diligence, additional identity verification, and more intensive ongoing monitoring. All players, regardless of risk classification, must meet minimum identification and verification standards before account activation and continued access.
- Customer Identification and Verification (KYC)
4.1 Identity Verification Requirements
Pure Casino Yellowhead is required to verify the identity of players for prescribed activities and transactions as defined under the PCMLTFA and FINTRAC regulations. The following information must be collected and verified for each player:
- Full legal name
- Date of birth
- Residential address
- Confirmation of legal gambling age in the applicable province or territory
The legal gambling age in Canada varies by province or territory and is either 18 or 19 years. Access is not permitted to any player who does not meet the applicable age requirement.
4.2 Verification Methods
Identity verification may be conducted through one or more of the following methods:
- Government-issued photographic identification documents
- Database verification against authoritative identity records
- Document verification services
- Biometric liveness checks where applicable
Pure Casino Yellowhead may engage accredited third-party identity verification providers to conduct or support these checks. The use of such providers does not reduce the company’s compliance obligations.
4.3 Source of Funds and Source of Wealth
For players classified as higher risk, including high-volume players and VIP account holders, additional documentation is required to confirm the legitimacy of funds used for gambling activity. This may include:
- Bank statements
- Proof of income or employment
- Business ownership documentation
- Other financial records as determined by the compliance function
Failure to provide requested documentation may result in account restriction or closure.
4.4 Ongoing Due Diligence
KYC is not a one-time process. Ongoing due diligence is conducted on player accounts, including periodic review of identity information and reassessment of risk classification where account activity or player circumstances change.
- Transaction Monitoring
Pure Casino Yellowhead maintains systems and procedures to monitor deposits, wagers, withdrawals, and fund transfers for patterns or behaviours indicative of money laundering or terrorist financing. Monitoring is conducted on a continuous basis.
Indicators that may trigger review or escalation include, but are not limited to:
- Large deposits followed by minimal gambling activity and withdrawal requests
- Rapid deposit and withdrawal cycles inconsistent with normal gambling behaviour
- Use of multiple accounts under different identities from the same access point
- Mismatched payment details relative to verified player identity
- Transactions structured to remain below reporting thresholds
- Use of third-party accounts for deposits or disbursements
- Circular fund movements between gambling accounts and external financial accounts
- Requests for winnings payments to third parties
- Contrived betting patterns, including coordinated even-money arrangements
These indicators are drawn from FINTRAC’s published guidance on money laundering and terrorist financing indicators for casinos and are embedded in internal monitoring procedures.
- Reporting Obligations
Pure Casino Yellowhead is required to submit reports to FINTRAC in the following circumstances:
- Suspicious Transaction Reports (STRs): submitted when there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing
- Large Cash Transaction Reports: submitted for cash transactions meeting prescribed thresholds under PCMLTFA regulations
- Other reports as required by FINTRAC regulations applicable to casinos
Reports are submitted in accordance with FINTRAC’s prescribed formats and timelines. Players and associated parties are not informed that a report has been or may be submitted.
- Sanctions and PEP Screening
Pure Casino Yellowhead screens players against applicable sanctions lists and databases of politically exposed persons (PEPs) and their associates. Screening is conducted at onboarding and on an ongoing basis. Players identified as matching a sanctions designation are subject to immediate account restriction pending further review. PEP status triggers enhanced due diligence requirements.
- Record-Keeping
Pure Casino Yellowhead retains KYC documentation, transaction records, and related compliance records for at least the minimum period prescribed by PCMLTFA regulations. Records are maintained in a secure manner and are made available to FINTRAC and other competent authorities upon lawful request.
- Internal Governance
9.1 Compliance Function
Pure Casino Yellowhead maintains a designated compliance function responsible for the implementation, oversight, and ongoing review of this Policy. Responsibilities include staff training, monitoring system oversight, escalation procedures, and liaison with FINTRAC.
9.2 Staff Training
All relevant staff receive training on AML and KYC obligations, red-flag indicators, escalation procedures, and reporting requirements. Training is conducted at onboarding and updated on a regular basis.
9.3 Independent Review
Pure Casino Yellowhead conducts periodic independent reviews of its AML / KYC program to assess the effectiveness of procedures, monitoring systems, and staff adherence. Review findings are used to update and strengthen this Policy.
- Integration with Responsible Gambling Obligations
The AML / KYC program operates alongside responsible gambling obligations. Behavioural monitoring conducted for AML purposes may also identify indicators of problem gambling. Where such indicators are identified, responsible gambling procedures are applied, including referral to self-exclusion tools, deposit limits, and support resources, in addition to any required AML actions.
- Data Protection
Personal data collected for AML / KYC purposes is processed in accordance with applicable Canadian privacy legislation and the Pure Casino Yellowhead Privacy Policy. Data is retained only for as long as required by law and is protected against unauthorised access through appropriate technical and organisational security measures.
- Policy Updates
This Policy is reviewed and updated on a regular basis to reflect changes in applicable legislation, FINTRAC guidance, and regulatory expectations. Players are subject to the version of this Policy in effect at the time of their account activity.