Woodbine Casino AML / KYC Policy

This document sets out the anti-money laundering (AML) and know-your-customer (KYC) policy applicable to gaming operations at Woodbine Casino. The casino operates under the regulatory framework established by Canadian federal law and Ontario provincial gaming authorities. All patrons and staff are subject to the requirements outlined below.

1. Regulatory Framework

Woodbine Casino is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations. The casino is classified as a reporting entity under Canadian federal law and is supervised by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Operations are also overseen by the Alcohol and Gaming Commission of Ontario (AGCO).

A compliance program is maintained to identify, assess, and mitigate risks related to money laundering, terrorist financing, and other unlawful financial activity. This program includes policies, procedures, risk assessments, training, and ongoing monitoring.

2. Identity Verification Requirements

Identity verification of patrons is required in specified circumstances. Verification is mandatory when a patron engages in transactions or activities that meet or exceed regulatory thresholds, or when there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing.

Acceptable forms of identification include government-issued photo identification, such as a valid passport, driver’s licence, or provincial identity card. Additional documentation may be requested to verify identity or source of funds in certain cases.

All identity records are collected, verified, and retained in accordance with FINTRAC requirements and internal record-keeping procedures.

3. Transaction Monitoring and Reporting

Patron transactions and gaming activity are monitored to detect unusual or suspicious patterns. Monitoring procedures include tracking of buy-ins, disbursements, and accumulated play over specified time periods.

The following reports are filed with FINTRAC, as required:

• Suspicious Transaction Reports: Filed when there are reasonable grounds to suspect that a transaction or attempted transaction is related to the commission or attempted commission of a money laundering or terrorist financing offence.
• Large Cash Transaction Reports: Filed for transactions involving the receipt of CAD 10,000 or more in cash in a single transaction.
• Casino Disbursement Reports: Filed for disbursements of CAD 10,000 or more made to a patron in a 24-hour period.
• Electronic Funds Transfer Reports: Filed for international electronic funds transfers of CAD 10,000 or more, subject to the 24-hour rule.

All reports are submitted in accordance with prescribed timelines and formatting requirements.

4. Record-Keeping Obligations

Records are maintained in relation to:

• Client identification and verification
• Transactions and disbursements
• Account opening and operation (where applicable)
• Suspicious transaction assessments and reports
• Compliance program documentation and risk assessments

Records are retained for a minimum of five years from the date of the last transaction or the date a business relationship ends, or as otherwise required by law.

5. Third Party Determination

When transactions are conducted on behalf of a patron, reasonable measures are taken to determine whether the patron is acting on behalf of a third party. If it is determined, or there are reasonable grounds to suspect, that a third party is involved, prescribed information about that third party is collected and recorded.

6. Ongoing Customer Due Diligence

Ongoing monitoring of patron activity is conducted, and assessments of money laundering and terrorist financing risk are reviewed periodically. Enhanced due diligence measures may be applied to patrons or transactions that present higher risk. Such measures may include requests for additional documentation, source of funds verification, or review by senior management.

7. Training and Compliance

All employees and contractors who may be exposed to money laundering or terrorist financing risk receive mandatory AML and KYC training. Training is provided upon hire and updated regularly to reflect changes in law, regulation, and internal policy.

The compliance program is overseen by a designated compliance officer responsible for policy implementation, staff training, reporting, and liaison with FINTRAC and other regulatory authorities.

8. Enforcement and Penalties

Failure to comply with AML and KYC obligations may result in administrative monetary penalties, regulatory sanctions, or other enforcement action by FINTRAC or the AGCO. Controls are implemented to deter, prevent, and detect violations.

Patrons who refuse to provide required identification or documentation, or who engage in conduct that raises reasonable suspicion of money laundering or terrorist financing, may be denied service, excluded from the casino, or reported to law enforcement or regulatory authorities.

9. Privacy and Data Protection

Personal information collected for AML and KYC purposes is handled in accordance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Ontario privacy legislation. Information is used solely for compliance, reporting, and risk management purposes and is disclosed only as required or permitted by law.

10. Policy Updates

This policy is reviewed and updated periodically to reflect changes in law, regulation, and industry best practices. Patrons are responsible for reviewing the current version of this policy, which is available on request at the casino or through official channels.

For questions or concerns regarding this policy, patrons may contact the Woodbine Casino compliance department during regular business hours.