Casinos

Your Obligations

The following summary of the legislative requirements under the PCMLTFA 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.

Additional Information for Casinos

Reporting

Record Keeping

You must keep the following records:

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

Ascertaining Identity

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

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

Use of personal information

The use of personal information in Canadian commercial activities is protected by the Personal Information Protection and Electronic Documents Act (PIPEDA), or by substantially similar provincial legislation. You have to inform individuals concerning the collection of personal information about them. However, you do not have to inform individuals when you include personal information about them in any of the reports that you are required to make to FINTRAC. You can get more information about your responsibilities in this area from the following:

Business Relationship

You are in a business relationship when a client holds an account with you.

You enter into a business relationship when a client opens an account with you; or when you conduct two or more transactions in which you have to:

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:

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.

Date Modified: