Casinos


Your Obligations

The following summary of the legislative requirements under the PMCLTFA applies to you if you are a casino. A casino is an entity that is authorized to do business in Canada, where roulette or card games are carried on in the establishment, or where there is a slot machine – not including video lottery terminals – on the premises. It does not include a registered charity authorized to carry on business in a casino for a period of two consecutive days or less, under the supervision of the casino.

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Printable summary for casinos (PDF version, 64 kb)

Additional Information for Casinos

Reporting

  • Suspicious transactions
    You must report where there are reasonable grounds to suspect that a transaction or an attempted transaction is related to the commission or attempted commission of a money laundering offence or a terrorist activity financing offence.

    See Guideline 2: Suspicious Transactions and Guideline 3: Submitting Suspicious Transaction Reports to FINTRAC

  • Terrorist property
    You must report where you know that there is property in your possession or control that is owned or controlled by or on behalf of a terrorist or a terrorist group.

    See Guideline 5: Submitting Terrorist Property Reports to FINTRAC

  • Large cash transactions
    You must report large cash transactions involving amounts of $10,000 or more received in cash.

    See Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC

  • Electronic Funds Transfers
    You must report international electronic funds transfers of $10,000 or more that you send or receive. These include the transmission of instructions for a transfer of funds made at the request of a client through any electronic, magnetic or optical device, telephone instrument or computer. In the case of SWIFT messages, only SWIFT MT 103 messages are included.

    See Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC

  • Casino disbursements
    Effective September 28, 2009, you must report casino disbursements involving amounts of $10,000 or more whether you pay them in cash or not.

    See Guideline 10: Submitting Casino Disbursement Reports to FINTRAC

Record Keeping

You must keep the following records:

  • Large cash transaction records
  • Signature cards
  • Large cash disbursement records (until September 27, 2009)
  • Copies of casino disbursement reports (effective September 28, 2009)
  • Deposit slips
  • Copies of official corporate records (including binding provisions)
  • Account holder information
  • Records regarding the extension of credit
  • Foreign exchange transaction tickets
  • Account operating agreements
  • Debit and credit memos
  • Copies of suspicious transaction reports
  • Records for the remittance or transmission of $1,000 or more and include information with certain transfers

See Guideline 6F: Record Keeping and Client Identification for Casinos

Ascertaining Identity

You must take specific measures to identify the following individuals or entities:

  • Any individual who signs a signature card or conducts a large cash transaction
  • Any individual carrying out a foreign exchange transaction of $3,000 or more Canadian or equivalent in foreign currency
  • Any individual with whom you conduct a large cash disbursement (until September 27, 2009)
  • Any individual to whom you pay a casino disbursement (effective September 28, 2009)
  • Any individual who conducts a transaction of $3,000 or more for which you have to keep an extension of credit record
  • Any corporation or other entity for which you open an account
  • Any individual for whom an amount of $1,000 or more is remitted or transmitted
  • Any individual for whom you have to send a suspicious transaction report (reasonable measures and exceptions apply)

See Guideline 6F: Record Keeping and Client Identification for Casinos

Third Party Determination

Where a large cash transaction record is required, you must take reasonable measures to determine whether the individual is acting on behalf of a third party. When a signature card or account operating agreement is created, you must take reasonable measures to determine whether the account is to be used by or on behalf of a third party. Effective September 28, 2009, when you have to report a casino disbursement, you have to take reasonable measures to determine whether the individual who receives the disbursement is acting on behalf on a third party.

In cases where a third party is involved, you must obtain and keep specific information about the third party and their relationship with the individual who provides the cash, holds the account or receives a casino disbursement.

See Guideline 6F: Record Keeping and Client Identification for Casinos

Compliance Regime

The following five elements must be included in a compliance regime:

  • The appointment of a compliance officer
  • The development and application of written compliance policies and procedures
  • The assessment and documentation of risks of money laundering and terrorist financing, and measures to mitigate high risks
  • Implementation and documentation of an ongoing compliance training program
  • A documented review of the effectiveness of policies and procedures, training program and risk assessment

See Guideline 4: Implementation of a Compliance Regime

Penalties for Non-compliance

Non-compliance with Part 1 of the Proceeds of Crime (Money Laundering) Terrorist Financing Act may result in criminal or administrative penalties.

FINTRAC Interpretation Notices

FINTRAC issues FINTRAC interpretation notices (FINs) to provide technical interpretations and positions regarding certain provisions contained in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.

For more information on your obligations and on FINTRAC, you can also consult our Frequently Asked Questions.