- Purpose and Scope
This policy sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) framework applied by Gold Eagle Casino to its online casino operations in Canada. It defines the obligations of the platform and its account holders in relation to identity verification, transaction monitoring, and compliance with applicable Canadian law.
Gold Eagle Casino operates in compliance with Canadian KYC and AML requirements, including obligations arising under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This policy applies to all registered account holders and to all transactions conducted through the platform.
- Legal Framework
Gold Eagle Casino operates in accordance with the following regulatory instruments and frameworks:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the primary federal statute governing AML obligations for Canadian reporting entities, including casinos.
- FINTRAC guidance, including the guidance document “When to Verify the Identity of Persons and Entities: Casinos”, which specifies the circumstances under which identity verification is mandatory.
- Provincial internet gaming standards, where applicable, including standards that require AML policies and procedures to support PCMLTFA obligations for online gaming operators.
- Canadian player protection laws, as referenced in Gold Eagle Casino’s stated compliance commitments.
Under the PCMLTFA, casinos are classified as reporting entities and are subject to mandatory identity verification, record-keeping, and suspicious transaction reporting obligations.
3. Identity Verification Requirements
3.1 When Verification Is Required
Gold Eagle Casino is required to verify the identity of account holders in the following circumstances, consistent with FINTRAC guidance for casinos:
- Receipt of CAD 10,000 or more in cash in a single transaction.
- Receipt of virtual currency equivalent to CAD 10,000 or more in a single transaction, where applicable under provincial rules.
- Any suspicious transaction, regardless of amount.
- Casino disbursements meeting applicable thresholds.
- Extension of credit of CAD 3,000 or more.
- Receipt of funds of CAD 3,000 or more.
- Foreign currency exchange transactions of CAD 3,000 or more.
- Initiation or final receipt of an electronic funds transfer (EFT) of CAD 1,000 or more, in specified circumstances.
Identity verification is also required prior to the processing of any withdrawal from an account held with Gold Eagle Casino.
3.2 Exemptions
In accordance with FINTRAC guidance, Gold Eagle Casino is not required to verify identity for large cash transactions when the cash is received from a financial entity or a public body, or from a person acting on behalf of such an entity.
3.3 Acceptable Identification
Account holders are required to submit valid government-issued identification documents for the purpose of identity verification. Accepted documents must confirm the account holder’s full legal name, date of birth, and residential address. Specific document requirements are communicated to account holders at the time verification is requested.
4. KYC Procedures
4.1 Account-Level Verification
For online accounts, identity verification is conducted at the account level. Account holders may be required to complete verification at registration, prior to withdrawal, or at any point where a triggering event under applicable law or internal risk assessment occurs.
4.2 Verification Steps
The KYC process applied by Gold Eagle Casino includes, but is not limited to, the following steps:
- Confirmation of full legal name, date of birth, and residential address.
- Submission of a government-issued photo identification document.
- Submission of proof of address where required.
- Provision of additional documentation where enhanced due diligence is applicable.
4.3 Enhanced Due Diligence
Enhanced due diligence is applied to account holders identified as higher risk. This includes, but is not limited to, politically exposed persons (PEPs), non-resident account holders, and account holders whose transaction patterns indicate elevated risk. Enhanced due diligence may require source-of-funds documentation and additional identity confirmation.
4.4 Sanctions and PEP Screening
Gold Eagle Casino screens account holders against applicable sanctions lists and PEP lists as part of its KYC process. Screening is conducted at account opening and is refreshed periodically in accordance with internal risk management procedures.
5. Transaction Monitoring and Fraud Detection
Gold Eagle Casino operates fraud detection systems and conducts ongoing transaction monitoring across account activity. The purpose of these systems is to identify patterns or transactions that may indicate money laundering, terrorist financing, fraud, or other prohibited activity.
Transaction monitoring is applied on a continuous basis. Alerts generated by monitoring systems are reviewed in accordance with internal escalation procedures.
6. Reporting Obligations
6.1 Large Cash Transaction Reports
Gold Eagle Casino files Large Cash Transaction Reports (LCTRs) with FINTRAC for any receipt of CAD 10,000 or more in cash, as required under the PCMLTFA.
6.2 Suspicious Transaction Reports
Gold Eagle Casino files Suspicious Transaction Reports (STRs) with FINTRAC for any transaction that gives rise to reasonable grounds to suspect that it is related to money laundering or terrorist financing, regardless of the transaction amount.
7. Record-Keeping
Gold Eagle Casino retains KYC records, transaction records, and AML-related documentation for a minimum of five years, consistent with FINTRAC requirements and applicable provincial standards. Records are maintained in a manner that allows for timely retrieval upon request by competent authorities.
8. Cryptocurrency and Virtual Currency
Provincial regulatory standards in certain Canadian jurisdictions prohibit the use of cryptocurrency or virtual currencies as a form of funds in casino operations. Account holders are directed to review the applicable terms and conditions of Gold Eagle Casino for information regarding accepted and prohibited funding instruments. Gold Eagle Casino practices with respect to virtual currency are governed by applicable provincial rules in the jurisdictions where it operates.
9. Account Holder Obligations
Account holders are required to:
- Provide accurate and complete information at registration and upon request.
- Submit required identity documents within the timeframe specified by Gold Eagle Casino.
- Notify Gold Eagle Casino of any material changes to personal information, including name, address, or identification documents.
- Refrain from using the account for any activity that constitutes money laundering, fraud, or any other prohibited conduct under applicable law.
Failure to comply with verification requests may result in suspension of withdrawal processing, restriction of account functionality, or account closure, in accordance with Gold Eagle Casino terms and conditions.
10. Policy Updates
This policy is reviewed and updated as required to reflect changes in applicable law, FINTRAC guidance, or provincial regulatory requirements. Account holders are subject to the version of this policy in effect at the time of any relevant transaction or verification event.