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This document outlines identity verification and compliance obligations for all account holders.

AML / KYC Policy at Elements Casino Brantford

3.1 When Verification Is Required

Identity verification is required in the following circumstances:

  • Upon account registration.
  • When a large cash transaction of CAD 10,000 or more is involved.
  • When a large virtual currency transaction meets applicable FINTRAC thresholds.
  • When funds received into the account amount to CAD 3,000 or more, subject to applicable exemptions.
  • When any transaction or account activity is assessed as suspicious, regardless of amount.
  • When enhanced due diligence is triggered by risk profiling.

3.2 Verification Methods

Identity may be verified using one or more of the following methods, consistent with FINTRAC-approved procedures:

  • Government-issued photo identification (for example, passport or driver’s licence).
  • Credit file verification conducted through an authorised credit bureau.
  • Dual-process verification using two independent reliable sources.
  • Affiliate source verification where applicable under FINTRAC guidance.

3.3 Information Recorded

Upon verification, the following information is recorded and retained:

  • Document type: government-issued photo identification, driver’s licence, passport, or equivalent.
  • Full legal name: as it appears on the submitted document.
  • Date of verification: the date on which identity was confirmed.
  • Document number: unique identifying number of the document.
  • Issuing jurisdiction: province, state, or country of issue.
  • Expiry date: where present on the document.

Records are retained for a minimum of five years from the date of the transaction or account activity to which they relate.

  1. Source of Funds Verification

The company is required to confirm that funds used for gambling activity originate from legitimate sources. Source of Funds (SOF) verification may be requested at any time, including prior to processing a withdrawal or following a significant deposit.

Accepted documentation for SOF verification includes:

  • Bank statements showing the origin of transferred funds.
  • Credit card statements relevant to deposits made.
  • Tax returns or notices of assessment.
  • Government pay statements or employment records.
  • Documentation evidencing the origin of gifts, inheritances, or asset sales.

For players identified as high-risk or high-volume, Source of Wealth (SOW) verification may also be required. SOW documentation demonstrates how the individual accumulated overall financial assets, and not only the funds used in a specific transaction.

If the source of funds cannot be verified to a satisfactory standard, the company may suspend or restrict account activity until verification is completed.

  1. Account Restrictions and Freezing

The company may freeze, suspend, or close an account under the following conditions:

  • The player fails to provide required identity documents within a reasonable timeframe.
  • Submitted documents cannot be authenticated or are inconsistent with account information.
  • Source of funds cannot be confirmed as legitimate.
  • Account activity presents indicators of money laundering or terrorist financing.
  • The player is found to be ineligible under the conditions set out in Section 2.

Account restrictions remain in place until the relevant verification or compliance review is concluded. The company is not obligated to disclose the specific reason for a restriction where doing so would compromise a regulatory investigation or reporting obligation.

  1. Transaction Monitoring and Reporting

6.1 Monitoring Obligations

Ongoing monitoring of account activity is conducted to detect patterns or transactions that may indicate money laundering, terrorist financing, or other financial crime. Monitoring systems assess transaction volume, frequency, betting behaviour, and account history on a continuous basis.

6.2 Suspicious Activity Indicators

The following behaviours are among those assessed as potential indicators of suspicious activity, consistent with FINTRAC guidance for casinos:

  • Multiple transactions conducted below reporting thresholds within a short period.
  • Enquiries by a player suggesting an intent to avoid reporting obligations.
  • Minimal gambling activity combined with large deposits or rapid withdrawal cycles.
  • Repeated deposit and withdrawal patterns with limited play.
  • Use of accounts or payment instruments associated with multiple individuals.
  • Adverse media or information linking a player to criminal activity.

6.3 Regulatory Reporting

The company is required to file the following reports with FINTRAC where applicable:

  • Large Cash Transaction Reports for any cash receipt of CAD 10,000 or more.
  • Suspicious Transaction Reports (STRs) for any transaction suspected to be linked to money laundering or terrorist financing, regardless of the amount involved.
  • Large Virtual Currency Transaction Reports where applicable thresholds are met.

Filing of a report to FINTRAC is a legal obligation. The company is prohibited from disclosing to the subject of a report that a report has been or may be filed.

  1. Risk-Based Approach and Enhanced Due Diligence

Players are assessed and categorised according to risk level based on factors including transaction volume, betting behaviour, country of residence, and account history. Players identified as presenting higher risk are subject to enhanced due diligence (EDD), which may include additional document requests, more frequent account reviews, and closer transaction monitoring.

Players from jurisdictions identified by the Financial Action Task Force (FATF) as high-risk or subject to increased monitoring are subject to additional scrutiny as a matter of policy.

  1. Player Obligations

All account holders are required to:

  • Provide accurate and complete information at registration and upon request.
  • Submit identity and source of funds documentation promptly when requested.
  • Notify the company of any material change to personal information held on the account.
  • Cooperate with verification and compliance reviews as required.

Failure to meet these obligations may result in account restriction, suspension, or closure, and may result in the reporting of relevant information to FINTRAC or other competent authorities as required by law.

  1. Data Handling

Information collected for AML and KYC purposes is processed in accordance with the platform’s Privacy Policy and applicable Canadian data protection legislation. Data is used solely for compliance, verification, and regulatory reporting purposes. Retention periods comply with the minimum five-year requirement under the PCMLTFA and applicable FINTRAC guidance.

  1. Policy Review

This policy is subject to periodic internal review and, where required, external audit to ensure continued compliance with applicable legislation and FINTRAC guidance. Updates to this policy take effect upon publication.