Cascades Casino AML / KYC Policy

1. Purpose and Scope

This document sets out the anti-money laundering (AML) and know-your-customer (KYC) policy applicable to Cascades Casino and its operations in Canada. The policy establishes the obligations of Cascades Casino as a reporting entity under Canadian federal law, defines the identity verification procedures applied to customers, and describes the compliance framework maintained to prevent money laundering and terrorist financing.

This policy applies to all customers, staff, and third parties who interact with Cascades Casino in any capacity that involves financial transactions or the establishment of a business relationship.

2. Legal Framework

Cascades Casino operates as a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations. As a casino operating in Canada, Cascades Casino is subject to the oversight of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), which issues casino-specific guidance on AML and KYC compliance.

In addition to federal obligations under the PCMLTFA, Cascades Casino is subject to applicable provincial gaming regulations. In British Columbia, where several Cascades-branded properties operate, provincial authorities have implemented enhanced AML oversight for casinos, creating additional compliance requirements that operate alongside the federal framework.

Cascades Casino maintains a written AML compliance program that is reviewed and updated on a regular basis, no less than annually, or whenever material changes occur in applicable regulations or in the casino’s risk profile.

3. Customer Identity Verification (KYC)

3.1 When Identity Verification Is Required

Cascades Casino is required to verify the identity of customers in the following circumstances:

• When establishing a business relationship with a customer.
• When a customer conducts a large cash transaction of CAD 10,000 or more, whether in a single transaction or in multiple transactions totaling CAD 10,000 or more within a 24-hour period.
• When a customer conducts a large virtual currency transaction of CAD 10,000 or more.
• When a casino disbursement of CAD 10,000 or more is made to a customer.
• When a transaction is deemed suspicious, regardless of the amount involved.
• When other circumstances prescribed by FINTRAC guidance or applicable regulations apply.

3.2 Prescribed Identity Verification Methods

Cascades Casino verifies customer identity using methods prescribed under the PCMLTFA Regulations. Accepted methods include:

• Government-issued photo identification method: The customer presents a valid government-issued document bearing their photograph and name, such as a passport or driver’s licence, either in person or through an approved online process.
• Credit file method: Identity is confirmed through a Canadian credit bureau that holds a credit file for the customer in their name, containing at least three years of credit history.
• Dual-process method: Two separate and reliable sources are used to confirm the customer’s name and either their date of birth or their address.
• Reliance method: Identity verification performed by another reporting entity under the PCMLTFA is relied upon, subject to applicable conditions.
• Affiliate or member method: Verification is conducted through an affiliated entity or a member of a group, where permitted by regulation.

3.3 Information Collected

At a minimum, Cascades Casino collects the following information when verifying a customer’s identity:

• Full legal name.
• Date of birth.
• Current residential address.
• Government-issued identification document type, number, and issuing jurisdiction.

For customers that are legal entities rather than individuals, Cascades Casino confirms the existence of the entity and collects beneficial ownership information, including the names and addresses of all persons who directly or indirectly own or control 25% or more of the entity, as well as the names of all directors.

4. Customer Due Diligence and Risk Assessment

Cascades Casino applies a risk-based approach (RBA) to customer due diligence (CDD). All customers are subject to a risk assessment that considers factors including transaction patterns, source of funds, geographic risk, and the nature of the business relationship.

4.1 Standard Due Diligence

Standard CDD applies to customers assessed as presenting a lower or standard level of risk. This includes identity verification, collection of required information, and ongoing monitoring of transactions to identify activity that is inconsistent with the customer’s known profile.

4.2 Enhanced Due Diligence

Enhanced due diligence (EDD) is applied to customers assessed as presenting a higher level of risk. Circumstances that may trigger EDD include:

• Use of large amounts of cash or virtual currency.
• Customer is a foreign national from a jurisdiction identified as high-risk.
• Customer is identified as a Politically Exposed Person (PEP), a Head of an International Organization (HIO), or a close family member or associate of such a person.
• Gaming or financial activity that appears inconsistent with the customer’s declared source of funds or known profile.
• Any other factor that, in the assessment of Cascades Casino, indicates elevated risk.

EDD measures may include additional identity documentation, verification of source of funds and source of wealth, senior management approval for the continuation of the business relationship, and more frequent monitoring and review of the customer’s activity.

5. Politically Exposed Persons and Sanctions Screening

Cascades Casino screens customers against applicable sanctions lists and identifies customers who qualify as Politically Exposed Persons or Heads of International Organizations. Where a customer is identified as a PEP or HIO, or as a close family member or associate of such a person, Cascades Casino applies enhanced due diligence measures and obtains senior management approval before establishing or continuing a business relationship.

6. Reporting Obligations

As a reporting entity under the PCMLTFA, Cascades Casino submits the following reports to FINTRAC as required:

• Large Cash Transaction Report: Cash transaction of CAD 10,000 or more within a 24-hour period.
• Large Virtual Currency Transaction Report: Virtual currency transaction of CAD 10,000 or more.
• Casino Disbursement Report: Disbursement of CAD 10,000 or more to a customer.
• Suspicious Transaction Report (STR): Any transaction where there are reasonable grounds to suspect money laundering or terrorist financing, regardless of amount.

Reports are submitted to FINTRAC within the timeframes prescribed by applicable regulations.

7. Record-Keeping

Cascades Casino maintains records of all identity verification documents, customer due diligence information, transaction records, and reports submitted to FINTRAC, in accordance with the retention periods prescribed under the PCMLTFA and its Regulations. Records are kept in a manner that allows them to be produced to FINTRAC upon request.

8. Internal Controls and Training

Cascades Casino maintains internal controls designed to support the effective implementation of this policy. These controls include defined roles and responsibilities for AML compliance, escalation procedures for unusual or suspicious activity, and regular internal review or audit of AML/KYC processes.

All staff members whose roles expose them to potential money laundering risk, including cage cashiers, gaming hosts, and surveillance personnel, are required to complete AML training. Training is conducted upon hire and updated on a regular basis to reflect changes in applicable regulations and identified risks.

9. Updates to This Policy

This policy is reviewed at least annually and updated as necessary to reflect changes in the PCMLTFA, FINTRAC guidance, applicable provincial regulations, or the risk environment in which Cascades Casino operates. Customers and staff are subject to the version of this policy in effect at the time of any relevant transaction or interaction.