AML/KYC Policy
1. Introduction and Scope
Treasure Cove Casino & Bingo, located in Prince George, British Columbia, is a licensed gaming facility regulated by the British Columbia Lottery Corporation (BCLC) and the Gaming Policy and Enforcement Branch (GPEB). This Anti-Money Laundering and Know Your Customer Policy (AML/KYC Policy) outlines the obligations, procedures, and requirements applicable to all patrons, employees, and third parties involved in financial transactions or gaming activities at the Casino, including both on-site operations and Virtual Bingo services.
The facility operates under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and reports to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Operations are conducted in accordance with BCLC standards, provincial gaming regulations, and the Gaming Control Act of British Columbia.
2. Identity Verification Requirements
2.1 Mandatory Verification Thresholds
Patrons with buy-ins or disbursements of CAD $3,000 or more in a single day are subject to mandatory identity verification before processing transactions or continuing gaming activities. Acceptable identification includes valid, government-issued photo ID (driver’s licence, passport, or provincial identification card). Records are retained in accordance with applicable retention requirements.
2.2 Transaction Tracking
Accumulated transactions amounting to CAD $1,500 or more over a 24-hour period are tracked and recorded. Patrons may be required to provide identification and associate their activity with a patron profile within the player-tracking system.
2.3 Age Verification
Entry and participation in any gaming activity, including Virtual Bingo, requires that all patrons be 19 years of age or older. Age is verified at entry and at transaction points, as required by law in British Columbia.
3. Source of Funds Declaration
3.1 Declaration Requirement
Patrons making a buy-in with cash, bank drafts, or certified cheques totaling CAD $10,000 or more within a 24-hour period must complete a Source of Funds Declaration and provide documentary proof of the origin of funds.
3.2 Acceptable Documentation
Acceptable documentation may include bank statements, pay stubs, sale agreements, loan documents, or other verifiable records establishing the legitimate origin of funds.
3.3 Refusal of Non-Compliant Transactions
Transactions that do not meet source-of-funds requirements are refused. Staff are required to decline transactions with insufficient, inconsistent, or questionable documentation regarding legitimacy of funds.
3.4 Sourced-Cash Conditions
Patrons subject to sourced-cash conditions, as determined by prior risk assessment or BCLC AML unit review, may not buy in with cash unless a valid source of funds can be provided, regardless of transaction size.
4. Large Cash Transaction Reporting
All cash transactions of CAD $10,000 or more, received from a patron within 24 hours, are reported to FINTRAC. This includes buy-ins, disbursements, and all cash movements through the Casino cage, gaming tables, slot machines, and bingo operations. Records of large cash transactions are maintained for at least five years and are accessible to FINTRAC and authorized regulatory bodies.
5. Suspicious Transaction Monitoring and Reporting
5.1 Continuous Monitoring
All transactions and patron activities are monitored for potential money laundering or terrorist financing indicators, regardless of transaction amount. Monitoring includes staff observation, automated systems, and centralized analysis by BCLC’s AML unit.
5.2 Indicators of Suspicious Activity
Enhanced scrutiny or reporting may be triggered by, including but not limited to:
– Transactions structured to avoid reporting thresholds
– Rapid buy-in and cash-out with little or no gaming activity
– Use of multiple third parties for transactions
– Insufficient or inconsistent explanations for source of funds
– Patron knowledge of thresholds or attempts to circumvent verification
– Unusual activity patterns across multiple locations or channels
5.3 Suspicious Transaction Reports
A Suspicious Transaction Report (STR) is filed with FINTRAC when reasonable grounds exist to suspect a transaction or attempt is linked to money laundering or terrorist financing. STRs are filed regardless of transaction size and remain confidential. Patrons are not informed of STR filings, and disclosure of such reporting is prohibited by law.
6. Encore Rewards and Known Play
6.1 Loyalty Program Enrollment
Enrollment in the Encore Rewards loyalty program requires personal information and valid identification. Participation supports tracking of gaming activity, identity verification, and transaction association with a patron profile.
6.2 Account-Based Play
The Casino is moving towards fully account-based, known play in land-based operations. Patrons engaged in higher-stakes or frequent gaming may be required to enroll in Encore Rewards or present verified identification to continue participation.
7. Virtual Bingo and Online Transactions
7.1 Eligibility and Verification
Virtual Bingo is open to British Columbia residents who are 19 years of age or older. Off-site participants must purchase bingo cards online using Visa, Mastercard, or PayPal. Identity and age are verified through the payment and account registration process.
7.2 Transaction Monitoring
Virtual Bingo card purchases are subject to the same AML and KYC standards as on-site activities. Large, unusual, or suspicious purchase volumes or payout patterns may result in enhanced due diligence or reporting.
8. Voluntary Self-Exclusion and Access Control
8.1 Self-Exclusion Program
Patrons enrolled in the Voluntary Self-Exclusion (VSE) program administered by BCLC and GPEB are prohibited from casino entry and gaming participation. Identity verification is used to refuse access to self-excluded individuals.
8.2 Discretionary Refusal of Entry
Security or management may refuse entry where a patron is suspected of money laundering, terrorist financing, unlawful activity, or non-compliance with identification or source-of-funds requirements.
9. Record Retention and Privacy
9.1 Retention Requirements
Records relating to identity verification, large cash transactions, suspicious transactions, and source-of-funds declarations are retained for at least five years, in compliance with federal and provincial law.
9.2 Use and Disclosure of Personal Information
Personal information collected for AML and KYC purposes is used solely for compliance with legal and regulatory obligations. Data is not used for marketing. Questions about personal information collection, use, or disclosure can be directed to the Privacy Officer at [email protected] or (250) 561-2421.
10. Staff Training and Internal Controls
All staff involved in cash handling, transaction processing, or patron services are trained on AML and KYC obligations, including identification of suspicious activity and verification of identity and funds. Segregation of duties and internal controls are maintained in cash-handling operations.
11. Cooperation with Regulators and Law Enforcement
Full cooperation is provided to BCLC, GPEB, FINTRAC, and law enforcement in all anti-money laundering, terrorist financing, and gaming integrity matters. Required records and reports are supplied, and regulatory inquiries and audits are addressed promptly.
12. Amendments and Updates
This AML/KYC Policy may be amended to reflect changes to federal or provincial law, BCLC standards, or regulatory guidance. Continued participation in Casino gaming activities constitutes acceptance of the latest version of this policy.
13. Contact Information
For any questions or concerns regarding this AML/KYC Policy, contact:
Treasure Cove Casino & Bingo
2003 Highway 97 South
Prince George, British Columbia
Telephone: (250) 561-2421
Toll-free: 1-866-561-2421
Email: [email protected]
For regulatory inquiries or complaints, contact the Gaming Policy and Enforcement Branch or BCLC.