- Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applicable to Parq Vancouver. It establishes the obligations, procedures, and controls governing customer identification, transaction monitoring, risk assessment, and reporting duties under applicable Canadian law.
This Policy applies to all customer accounts, all transactions processed through Parq Vancouver, and all personnel involved in compliance-related functions. It is designed to meet the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the associated regulations administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
Parq Vancouver operates within the Canadian regulatory framework. Federal AML obligations under the PCMLTFA and applicable provincial gaming licensing conditions apply simultaneously. This Policy reflects both levels of obligation.
- Legal Framework
Parq Vancouver’s AML and KYC obligations arise from the following sources:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the primary federal statute governing AML and counter-terrorist financing obligations for reporting entities, including casinos.
- FINTRAC regulations and guidance, including operational rules and indicators such as the Money Laundering and Terrorist Financing Indicators for Casinos and relevant special bulletins on money laundering through gambling channels.
- Provincial gaming licensing conditions imposed by the relevant provincial gaming regulator applicable to Parq Vancouver’s operations.
This Policy is reviewed on a regular basis to incorporate updates to legislation, FINTRAC guidance, and provincial regulatory requirements.
- Customer Identification and Verification
3.1 Identification Requirements
Parq Vancouver is required to verify the identity of customers in connection with prescribed activities and transactions. Verification is conducted at the point of account creation and, where required, at the point of a qualifying transaction or activity.
Acceptable forms of identification include government-issued documents that confirm the customer’s full legal name, date of birth, and residential address. Where a single document does not confirm all required information, additional documentation may be requested.
3.2 Verification Methods
Identity verification may be conducted through one or more of the following methods:
- Review of original government-issued photo identification
- Electronic identity verification using authoritative data sources
- Biometric or liveness-based digital verification tools where applicable
- Database checks against sanctions lists, politically exposed persons (PEP) registers, and adverse media sources
Account activity is not permitted to proceed where identity verification has not been completed to the required standard.
3.3 Age Verification
Age verification is conducted as part of the customer identification process. The minimum age for participation is determined by applicable provincial law. Access to regulated activities is not permitted for persons who do not meet the applicable age requirement.
- Risk-Based Approach
A risk-based approach is applied to customer due diligence. Each customer is assigned a risk classification - low, medium, or high - based on factors including but not limited to:
- Customer profile and transaction history
- Geographic risk associated with the customer’s jurisdiction of residence or funding source
- Nature and frequency of transactions
- Product or channel risk
- Presence on PEP, sanctions, or adverse media lists
Customers classified as higher risk are subject to enhanced due diligence. This may include requests for source of funds documentation, source of wealth information, and more frequent review of account activity. Parq Vancouver reserves the right to restrict or suspend account activity pending completion of enhanced due diligence.
- Ongoing Monitoring
Parq Vancouver maintains a continuous transaction monitoring program designed to detect patterns and behaviours that may indicate money laundering, terrorist financing, or other financial crime.
Monitoring systems are configured to identify, among other indicators, behaviours consistent with FINTRAC guidance, including:
- Transactions structured to remain below reporting thresholds
- Large deposits followed by minimal activity and subsequent withdrawal
- Use of multiple accounts associated with a single individual or shared access credentials
- Mismatched player registration details and payment method details
- Requests to transfer funds or winnings to third-party accounts
- Requests to transfer funds to accounts in high-risk jurisdictions
- Inconsistent combinations of deposit and withdrawal methods
- Use of shared bank accounts across multiple customer accounts
- Activity inconsistent with a customer’s established financial profile
- Use of false, forged, or misleading identification documents
- Adverse media linking a customer to criminal activity
Where monitoring identifies activity that meets or approaches the threshold for suspicion, the matter is escalated for internal review in accordance with internal escalation procedures.
- Reporting Obligations
Parq Vancouver is a reporting entity under the PCMLTFA and files the following reports with FINTRAC as required:
- Suspicious Transaction Reports (STRs), filed where there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist activity financing.
- Large Cash Transaction Reports, filed for cash transactions meeting the prescribed threshold under applicable regulations.
- Large Virtual Currency Transaction Reports, filed where applicable for virtual currency transactions meeting the prescribed threshold.
- Casino Disbursement Reports, filed for disbursements meeting the prescribed threshold.
Reports are filed within the timeframes prescribed by FINTRAC regulations. Parq Vancouver does not disclose to a customer or any third party that a report has been or may be filed in relation to their account or transactions, except as required by law.
- Record Retention
Parq Vancouver retains records related to customer identification, due diligence, and transactions for a minimum of five years from the date of the transaction or the date on which the customer relationship ends, whichever is later. Records are maintained in a manner that allows for timely retrieval in response to a lawful request from FINTRAC or another competent authority.
- Customer Obligations
Customers are required to:
- Provide accurate, complete, and current identification information at the time of account registration and upon request
- Respond promptly to requests for additional documentation or information issued in connection with due diligence or monitoring
- Notify Parq Vancouver of any material change to their personal information, including name, address, or source of funds
Failure to provide required information, provision of false or misleading information, or refusal to cooperate with due diligence procedures may result in suspension or termination of account access and, where required, the filing of a report with FINTRAC.
- Governance and Internal Controls
9.1 Compliance Officer
A designated Compliance Officer is responsible for overseeing the implementation and ongoing operation of this Policy, ensuring staff training, and managing regulatory reporting obligations.
9.2 Staff Training
All personnel with responsibilities relevant to AML and KYC compliance receive training on applicable legal requirements, FINTRAC indicators, internal procedures, and their individual obligations. Training is conducted at onboarding and on a recurring basis to reflect regulatory updates.
9.3 Independent Audit
Independent testing of the AML program is conducted on a periodic basis. The purpose of such testing is to assess whether written policies are reflected in operational practice, whether monitoring systems are functioning effectively, and whether the program remains current with applicable regulatory requirements.
- Interaction with Responsible Gambling Obligations
Identity verification and transaction monitoring systems support the operation of responsible gambling controls, including age verification, self-exclusion enforcement, and behavioural monitoring. These functions rely on accurate and current customer identification data maintained under this Policy. Responsible gambling obligations are governed separately under the Parq Vancouver Responsible Gambling Policy.
- Data Protection
Personal data collected for the purposes of AML and KYC compliance is processed and stored in accordance with applicable Canadian privacy legislation and the Parq Vancouver Privacy Policy. Access to such data is restricted to authorised personnel and it is disclosed to regulatory authorities only as required by law.
- Policy Review
This Policy is reviewed at least annually and updated as necessary to reflect changes in applicable legislation, FINTRAC guidance, provincial regulatory requirements, and internal risk assessments. The current version of this Policy is available upon request.