AML/KYC Policy
1. Introduction and Scope
This document outlines the anti-money laundering (AML) and know-your-customer (KYC) policy applicable at Casino de Montréal. The casino operates as a land-based gambling venue under federal and provincial regulation and is owned and operated by Loto-Québec, a government corporation of the Province of Québec, at 1 Avenue du Casino, Montréal, Québec, H3C 4W7. Legal obligations exist to adopt measures to detect and prevent money laundering and terrorist financing. This policy specifies obligations, procedures, and requirements for patrons who visit the premises or conduct transactions.
2. Legal and Regulatory Framework
2.1. Federal Obligations
Casino de Montréal is a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. Supervision is conducted by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
Obligations under federal law include:
– Maintaining a formal compliance program with a designated compliance officer
– Conducting risk assessments of products, services, clients, and geographic exposure
– Verifying client identity in prescribed circumstances
– Submitting reports to FINTRAC as required
– Retaining records for specified periods
– Providing ongoing staff training
2.2. Provincial Regulation
The casino is subject to Québec rules governing casino operations, public admission, security, and responsible gambling. Provincial regulations prohibit individuals convicted of certain offences, such as money laundering, forgery, charging criminal-interest rates, and specified drug offences, from entering government-owned casinos for five years after conviction or guilty plea.
3. Client Identification and Verification
3.1. When Identity Verification Is Required
Client identity is verified in the following situations:
– Large cash transactions of $10,000 CAD or more in a single transaction
– Casino disbursements of $10,000 or more
– Credit extensions of $3,000 or more
– Receipt of funds of $3,000 or more
– Foreign currency exchanges of $3,000 or more
– Electronic funds transfers of $1,000 or more
– Suspicious transactions of any amount
– Virtual currency transactions of $10,000 or more
A 24-hour aggregation rule applies: multiple transactions are treated as a single reportable event if the total meets applicable thresholds within a 24-hour period for the same person.
3.2. Methods of Verification
Verification methods prescribed by FINTRAC may include:
– Government-issued photo identification (driver’s licence, passport, provincial ID card)
– Credit file checks
– Dual-process method using two independent sources
– Electronic verification tools where permitted
�
Copies of identification and verification records are kept for at least five years.
3.3. Business Relationships and Ongoing Monitoring
A business relationship is established with repeat identification or account opening. Ongoing monitoring includes:
– Updating client information
– Monitoring for unusual transaction patterns
– Enhanced due diligence where risk factors are present
4. Reporting Obligations
4.1. Casino Disbursement Reports
Casino Disbursement Reports (CDRs) are filed with FINTRAC for disbursements of $10,000 or more in a single transaction, including cash payouts, cheques, electronic transfers, and related financial instruments. Reports are filed electronically within fifteen calendar days.
4.2. Suspicious Transaction Reports
Suspicious Transaction Reports (STRs) are submitted when there are reasonable grounds to suspect involvement in money laundering or terrorist financing, regardless of transaction amount. Disclosure to any person of STR filing is prohibited by law.
4.3. Large Cash Transaction Reports
All cash transactions of $10,000 or more, including aggregated totals within a 24-hour period for the same person, are reported to FINTRAC.
4.4. Electronic Funds Transfer and Virtual Currency Reports
Incoming and outgoing electronic funds transfers of $10,000 or more, and virtual currency transactions at or above the same threshold, are reported in line with FINTRAC requirements and aggregation rules.
5. Enhanced Due Diligence and Risk-Based Measures
5.1. High-Risk Clients
Enhanced due diligence (EDD) applies to clients presenting higher risks, including:
– Politically exposed persons (PEPs) or heads of international organizations (HIOs)
– Individuals from high-risk jurisdictions
– Clients with inconsistent transaction patterns
– Clients identified through adverse media or law enforcement intelligence
EDD measures may include gathering detailed source of funds information, supporting documents, background checks, and escalation to senior management.
5.2. Product and Service Risk Assessment
Risk assessments are conducted for offered products and services. Higher-risk areas include high-limit table games, large-denomination slot machines, foreign currency exchanges, and VIP services. Controls are adjusted as required, potentially lowering thresholds for EDD or requesting additional documentation.
6. Beneficial Ownership and Entity Verification
For entities such as corporations, beneficial ownership information is obtained and reasonable measures are taken to confirm the identity of natural persons with ultimate control. Documentation is retained for at least five years.
7. Politically Exposed Persons and Heads of International Organizations
Efforts are made to determine whether a client is a PEP or HIO for relevant activities or transactions. If identified, enhanced measures apply, such as:
– Senior management approval
– Source of funds verification
– Increased transaction monitoring
8. Record Keeping
Records are maintained relating to:
– Client identification and verification
– Transactions and account activity
– Reports to FINTRAC
– Internal notes and assessments on suspicious behaviour and EDD
Retention is for at least five years from the last transaction or the end of the business relationship. Access to records is restricted to authorized personnel.
9. Compliance Program and Governance
9.1. Compliance Officer and Specialist Team
A compliance officer is appointed to implement and oversee the AML/KYC program, supported by a team of specialists, analysts, legal professionals, and security staff. Responsibilities include risk assessments, policy and procedure development, training delivery, and compliance reporting.
9.2. Training
Relevant staff receive ongoing AML/KYC training concerning identification, reporting, detection of suspicious behaviour, and procedures.
9.3. Periodic Review
Periodic reviews assess the effectiveness of the compliance program. Policies and procedures are updated in response to regulatory changes, audit outcomes, and risk evolution.
10. Exclusions and Access Restrictions
10.1. Criminal Conviction-Based Exclusions
Individuals convicted of or pleading guilty to specified offences within five years are denied entry, including:
– Money laundering
– Forgery
– Charging criminal interest rates
– Offences under the Controlled Drugs and Substances Act affecting casino integrity or public trust
Enforcement occurs at entry with identification checks.
10.2. Self-Exclusion Program
A voluntary self-exclusion program is available. Patrons may register at the customer service desk, Loto-Québec’s head office, or designated treatment centres. Registered individuals are recorded in a database to prevent casino entry and gaming participation.
11. Interaction with Loyalty and VIP Programs
Loyalty and VIP programs fall under AML/KYC controls. High-value patrons are risk-assessed with EDD applied where necessary. Eligibility for VIP benefits is reviewed for AML risk, including criminal ties, source of funds, and transaction activity. VIP privileges are not extended to individuals presenting unacceptable risk.
12. Cooperation with Authorities
Full cooperation is maintained with FINTRAC, law enforcement, and provincial regulators. Requests for information and legally required records are provided. STR filing and investigations are not disclosed to clients or unauthorized persons.
13. Data Protection and Privacy
Personal information is handled in compliance with federal AML and Québec privacy legislation. Data is used for identity verification, monitoring, reporting, and legal compliance; stored for necessary periods; and protected by security measures. Access is limited to authorized personnel.
14. Amendments and Updates
This policy is reviewed regularly and updated to reflect regulatory changes, audit findings, or operational experience. Material amendments are communicated through appropriate channels.
15. Contact Information
For inquiries related to the AML/KYC policy, contact the compliance department via Loto-Québec’s head office at 500 Rue Sherbrooke Ouest, Montréal, Québec, or by telephone through contact information published on the official website.
This policy applies from the date of publication to all transactions and client interactions at Casino de Montréal.