1. Purpose and Scope
This Anti-Money Laundering and Know Your Customer (AML / KYC) Policy sets out the obligations of Grey Eagle Resort & Casino and its customers in relation to identity verification, risk assessment, transaction monitoring, and reporting under applicable Canadian federal law.
This Policy applies to all individuals who access, register with, or conduct transactions through Grey Eagle Resort & Casino. It covers all stages of the customer relationship, from initial onboarding through ongoing account activity.
Grey Eagle Resort & Casino operates as a reporting entity subject to Canada’s federal anti-money laundering and anti-terrorist financing regime. Compliance with this regime, and with this Policy, is mandatory. Failure to satisfy the requirements set out in this Policy may result in refusal of service, account restriction, account closure, or mandatory reporting to the relevant authority.
2. Regulatory Framework
AML and KYC activities at Grey Eagle Resort & Casino are conducted in accordance with the following regulatory framework:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) - the primary federal statute governing anti-money laundering and anti-terrorist financing obligations for Canadian reporting entities, including casinos and gambling operators.
- FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) - the federal supervisory authority responsible for overseeing compliance with AML and anti-terrorist financing obligations. Grey Eagle Resort & Casino is required to file reports with FINTRAC as prescribed by applicable regulations.
- Financial Action Task Force (FATF) Recommendations - international standards that inform Canada’s risk-based approach to AML compliance, including guidance on politically exposed persons, high-risk jurisdictions, and enhanced due diligence.
3. Customer Identification and Verification (KYC)
3.1 Identity Verification Requirements
Grey Eagle Resort & Casino is required to verify the identity of customers at defined stages of the customer relationship. Verification is conducted prior to or at the time of account activation and may be repeated when risk indicators arise during the course of the relationship.
Customers are required to provide, at a minimum:
- Government-issued photo identification (such as a passport, driver’s licence, or an equivalent document issued by a Canadian federal or provincial authority)
- Proof of residential address (such as a utility statement, bank statement, or official correspondence dated within the preceding three months)
- Date of birth confirmation
Where automated or digital verification is used, customers may be required to submit document images and complete a biometric liveness check to confirm that the individual presenting the document is the same person named on it.
3.2 Age Verification
Grey Eagle Resort & Casino does not permit access to gambling services by individuals under the age of 18. Age verification is a mandatory component of the KYC process. Access will be denied or suspended where age cannot be confirmed to the required standard.
3.3 Address and Jurisdiction Verification
Customers must provide a verifiable residential address. Customers located in jurisdictions identified as high-risk by FATF or subject to Canadian sanctions may be subject to enhanced due diligence or may be declined service in accordance with applicable law.
4. Risk Classification
Grey Eagle Resort & Casino applies a risk-based approach to customer due diligence. Each customer is assigned a risk classification based on factors that may include:
- Transaction volume and frequency
- Betting and payment behavior patterns
- Jurisdiction of residence
- Source of funds and wealth indicators
- Presence on sanctions lists or politically exposed persons (PEP) registers
- Adverse media findings
Risk tiers are generally defined as follows:
Risk Level | Description | Due Diligence Applied
Low | Standard profile, consistent activity, verified identity | Standard Customer Due Diligence (CDD)
Medium | Elevated transaction volume or minor inconsistencies | Enhanced monitoring, periodic review
High | VIP or high-roller status, high-risk jurisdiction, PEP status, anomalous activity | Enhanced Due Diligence (EDD), Source of Funds verification
Risk classifications are subject to periodic review and may be revised at any time based on updated information or observed behavior.
5. Enhanced Due Diligence (EDD)
Where a customer is classified as high-risk, Grey Eagle Resort & Casino will apply Enhanced Due Diligence measures. These may include:
- Request for Source of Funds (SOF) documentation, such as bank statements, payroll records, or business ownership documents
- Request for Source of Wealth (SOW) documentation to establish the origin of the customer’s overall financial assets
- Additional identity verification steps
- Increased frequency of account monitoring
- Senior management approval prior to establishing or continuing the customer relationship
Customers subject to EDD are required to cooperate fully with these requests. Refusal to provide requested documentation may result in account restriction or closure.
6. Transaction Monitoring
Grey Eagle Resort & Casino monitors customer transactions on an ongoing basis. Monitoring systems are designed to detect patterns and behaviors consistent with money laundering or terrorist financing typologies identified by FINTRAC and other competent authorities.
The following behaviors are treated as indicators requiring review and potential reporting:
- Large deposits followed by minimal or no gambling activity and subsequent withdrawal requests
- Structured transactions designed to remain below reporting thresholds
- Multiple accounts controlled by or associated with the same individual
- Funding method details that do not correspond to the registered account holder’s identity
- Requests to transfer funds or winnings to third-party accounts or accounts in high-risk jurisdictions
- Circular fund flows between bank accounts and the gambling account without apparent economic purpose
- Inconsistency between a customer’s stated profile and observed transaction activity
Detection of one or more of these indicators will trigger an internal review. Depending on the outcome, the matter may be escalated for suspicious transaction reporting to FINTRAC.
7. Reporting Obligations
Grey Eagle Resort & Casino is required to submit the following reports to FINTRAC where applicable:
- Suspicious Transaction Reports (STRs) - filed where there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing
- Large Cash Transaction Reports - filed for cash transactions meeting or exceeding the prescribed threshold under applicable regulations
- Terrorist Property Reports - filed where property is known or believed to be owned or controlled by a terrorist or terrorist group
All reports are submitted in accordance with the timelines and formats prescribed by FINTRAC. Customers are advised that the existence of a report filed with FINTRAC will not be disclosed to them, as such disclosure is prohibited by law.
8. Record Retention
Grey Eagle Resort & Casino retains all KYC documentation, transaction records, and related compliance records for a minimum of five years from the date of the transaction or the end of the customer relationship, whichever is later. Records are maintained in a secure format and are accessible to FINTRAC and other competent authorities upon lawful request.
9. Sanctions and PEP Screening
All customers are screened against applicable sanctions lists, including those maintained by the Government of Canada, and against PEP registers at the time of onboarding and on an ongoing basis.
Customers identified as designated persons under Canadian sanctions legislation will be declined service and reported as required by law.
Customers identified as politically exposed persons, or as close associates or family members of PEPs, are subject to Enhanced Due Diligence as described in Section 5.
10. Customer Obligations
Customers of Grey Eagle Resort & Casino are required to:
- Provide accurate, complete, and current identity and address information at all times
- Notify Grey Eagle Resort & Casino promptly of any change to their personal details
- Cooperate with identity verification and due diligence requests
- Refrain from any activity designed to circumvent AML or KYC controls, including structuring transactions to avoid reporting thresholds
Provision of false or misleading information constitutes a breach of this Policy and may result in immediate account closure, forfeiture of funds where permitted by law, and referral to law enforcement authorities.
11. Policy Review
This Policy is reviewed on a regular basis to reflect changes in applicable law, FINTRAC guidance, and industry best practice. The current version of this Policy is available upon request.
Continued use of Grey Eagle Resort & Casino services constitutes acceptance of this Policy as amended from time to time.