1) Purpose and Scope
This AML and KYC Policy outlines the measures and controls implemented by Canada777 to prevent and detect money laundering (ML), terrorist financing (TF), and other financial crimes. It applies to all players, staff, agents, and third-party service providers engaged with our online casino operations.
The policy aligns with:
Financial Action Task Force (FATF) Recommendations
EU 5th/6th AML Directives (where applicable)
Proceeds of Crime and Terrorist Financing Acts in our operating jurisdictions
2) Objectives
Verify the identity of all customers (players) before establishing a business relationship.
Monitor customer transactions to detect and report suspicious activity.
Maintain accurate and up-to-date customer information and transaction records.
Train staff to recognize and handle suspicious activities appropriately.
Cooperate with regulatory and law enforcement authorities as required.
3) Customer Due Diligence (KYC)
3.1 Identity Verification
Before allowing deposits, withdrawals, or gameplay with real funds, players must complete identity verification. Acceptable documents include:
Proof of Identity: Government-issued photo ID (passport, national ID card, or driver’s license)
Proof of Address:: Utility bill or bank statement issued within the last 3 months
Proof of Payment Method Ownership: Screenshot or statement showing player’s name and payment account details
3.2) Enhanced Due Diligence (EDD)
EDD is applied when:
The player deposits or withdraws amounts exceeding €2,000 (or equivalent) in aggregate
The player is from a high-risk jurisdiction
There are signs of suspicious behavior or inconsistent gameplay patterns EDD measures include:
Video call verification
Source of funds/source of wealth documentation
Ongoing monitoring of all transactions
4) Risk Assessment and Categorization
All players are risk-rated (low, medium, high) based on:
Geographic location
Volume and frequency of transactions
Payment methods used
Behavior patterns (e.g. multiple accounts, rapid deposits/withdrawals)
High-risk players are subject to increased monitoring and additional verification requirements.
5) Ongoing Monitoring
Automated systems review deposits, withdrawals, and betting patterns
Unusual behaviors (e.g. rapid turnover, minimal gameplay, large deposits with immediate withdrawals) are flagged for manual review
Any account suspected of involvement in ML/TF is suspended pending investigation
6) Reporting Suspicious Activity
Staff must immediately report suspicious transactions or behaviors to the Money Laundering Reporting Officer (MLRO)
The MLRO will file a Suspicious Activity Report (SAR) to the relevant Financial Intelligence Unit (FIU) as required by law
The player will not be notified that a report has been filed (tipping off is prohibited)
7) Record Keeping
All KYC documents and transaction records are retained securely for a minimum of 5 years after the end of the player relationship
Access to these records is restricted to authorized compliance personnel
8) Politically Exposed Persons (PEPs) & Sanctions
Players are screened against PEP and sanctions lists during onboarding and periodically thereafter
PEPs require senior management approval and EDD
No business will be conducted with persons or entities on international sanctions lists (OFAC, EU, UN, etc.)
9) Training and Awareness
All customer-facing, financial, and compliance staff receive initial and annual AML/KYC training
Training includes recognizing suspicious behavior, reporting procedures, and legal obligations
10) Internal Controls and Auditing
The MLRO is responsible for implementing and enforcing this policy
Internal audits are conducted annually to assess the effectiveness of AML/KYC controls
This policy is reviewed at least once per year and updated as required by law
11) Disciplinary Measures
Any employee who fails to comply with this policy may be subject to disciplinary action, up to and including termination
Breaches may also result in regulatory penalties or criminal prosecution
12) Policy Approval
Approved by: Mark Martin, Compliance Officer / MLRO
Effective Date: 17/08/2025
Next Review Date: 17/08/2026
Before allowing deposits, withdrawals, or gameplay with real funds, players must complete identity verification. Acceptable documents include:
Proof of Identity: Government-issued photo ID (passport, national ID card, or driver’s license)
Proof of Address:: Utility bill or bank statement issued within the last 3 months
Proof of Payment Method Ownership: Screenshot or statement showing player’s name and payment account details
EDD is applied when:
The player deposits or withdraws amounts exceeding €2,000 (or equivalent) in aggregate
The player is from a high-risk jurisdiction
There are signs of suspicious behavior or inconsistent gameplay patterns EDD measures include:
Video call verification
Source of funds/source of wealth documentation
Ongoing monitoring of all transactions
All players are risk-rated (low, medium, high) based on:
Geographic location
Volume and frequency of transactions
Payment methods used
Behavior patterns (e.g. multiple accounts, rapid deposits/withdrawals)
High-risk players are subject to increased monitoring and additional verification requirements.
Automated systems review deposits, withdrawals, and betting patterns
Unusual behaviors (e.g. rapid turnover, minimal gameplay, large deposits with immediate withdrawals) are flagged for manual review
Any account suspected of involvement in ML/TF is suspended pending investigation
Staff must immediately report suspicious transactions or behaviors to the Money Laundering Reporting Officer (MLRO)
The MLRO will file a Suspicious Activity Report (SAR) to the relevant Financial Intelligence Unit (FIU) as required by law
The player will not be notified that a report has been filed (tipping off is prohibited)
All KYC documents and transaction records are retained securely for a minimum of 5 years after the end of the player relationship
Access to these records is restricted to authorized compliance personnel
Players are screened against PEP and sanctions lists during onboarding and periodically thereafter
PEPs require senior management approval and EDD
No business will be conducted with persons or entities on international sanctions lists (OFAC, EU, UN, etc.)
All customer-facing, financial, and compliance staff receive initial and annual AML/KYC training
Training includes recognizing suspicious behavior, reporting procedures, and legal obligations
The MLRO is responsible for implementing and enforcing this policy
Internal audits are conducted annually to assess the effectiveness of AML/KYC controls
This policy is reviewed at least once per year and updated as required by law
Any employee who fails to comply with this policy may be subject to disciplinary action, up to and including termination
Breaches may also result in regulatory penalties or criminal prosecution
Approved by: Mark Martin, Compliance Officer / MLRO
Effective Date: 17/08/2025
Next Review Date: 17/08/2026
