1. Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Chilliwack to all registered accounts and transactions processed through the service. The policy is designed to meet obligations under Canadian federal legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations, as well as applicable provincial gaming standards.
This policy applies to all persons who register an account, initiate or receive funds, or otherwise interact with Chilliwack in a capacity that triggers identity verification or transaction monitoring requirements. Compliance with this policy is a condition of account access and continued use of the service.
2. Legal Framework
Chilliwack operates within a regulatory environment that includes oversight by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), which is the federal authority responsible for receiving, analyzing, and disclosing financial intelligence related to money laundering and terrorist financing. Where applicable, provincial gaming regulators, including the Alcohol and Gaming Commission of Ontario (AGCO) and equivalent bodies in other provinces, impose additional standards governing player registration, identity validation, and ongoing account monitoring.
Obligations under this framework include customer identification, source-of-funds assessment, record retention, employee training, risk-based compliance programming, and the submission of required reports to FINTRAC.
3. Customer Identification Requirements
3.1 When Identification Is Required
Chilliwack is required to verify the identity of a customer in the following circumstances, among others:
- When a customer initiates an electronic funds transfer of CAD 1,000 or more.
- When a customer is the final recipient of an international electronic funds transfer of CAD 1,000 or more.
- When account activity or transaction patterns indicate a need for enhanced due diligence.
- At account registration, where required by applicable provincial standards.
- When existing account information changes or requires periodic re-validation.
3.2 Information Collected
At the time of identity verification, Chilliwack collects and validates the following categories of information:
- Full legal name.
- Date of birth.
- Residential address.
- Government-issued identification details.
- Contact information, including a valid email address.
- Login identification information associated with the account.
- Any additional information required under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act or applicable provincial regulations.
All information submitted must be accurate and complete. Account creation or continued access may be suspended or refused if submitted information cannot be validated.
3.3 Ongoing Verification
Identity verification is not limited to account opening. Chilliwack may request updated documentation or additional information at any point during the account lifecycle, including when account details change, when transaction behavior warrants review, or at regular intervals as required by applicable standards. Failure to provide requested information within a reasonable timeframe may result in account restriction or closure.
4. Source of Funds
Where transaction values, account activity, or risk indicators require it, Chilliwack may request documentation or explanation regarding the origin of funds deposited or wagered. This may include, but is not limited to, employment records, bank statements, or other evidence demonstrating that funds originate from a legitimate source. Such requests are made in accordance with risk-based compliance obligations and are not discretionary.
5. Transaction Monitoring and Risk Indicators
Chilliwack maintains ongoing monitoring of account activity to identify patterns or transactions that may indicate money laundering, terrorist financing, or other financial crime. In accordance with FINTRAC guidance, the following are examples of activity that may trigger enhanced review or reporting:
- Third-party payments or casino-cheque transactions involving CAD 3,000 or more where the payee is unspecified or a third party.
- Transfer of winnings or account balances to a bank account held by a person other than the registered account holder.
- Transactions involving jurisdictions identified as high-risk by FINTRAC or international standards bodies.
- Unusual or inconsistent payment arrangements that do not correspond to the account holder’s stated profile.
This list is not exhaustive. Any transaction or pattern of behavior that raises a reasonable suspicion of financial crime may be subject to review and, where required, reported to FINTRAC.
6. Suspicious Transaction Reporting
Where Chilliwack has reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, the company is required by law to submit a Suspicious Transaction Report to FINTRAC. This obligation applies regardless of the transaction amount and covers both completed and attempted transactions. Chilliwack does not notify account holders when a suspicious transaction report has been filed, as such disclosure is prohibited under applicable legislation.
7. Record Retention
Chilliwack retains records related to customer identification, transactions, and compliance activities for the periods required under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations. Retained records may include identification documents, transaction records, account history, and correspondence related to verification or monitoring activities.
8. Account Restrictions and Closure
Chilliwack may restrict, suspend, or close an account where:
- A customer fails to provide required identification or supporting documentation.
- Submitted information is found to be false, incomplete, or unverifiable.
- Account activity triggers a compliance obligation that cannot be resolved.
- Applicable law or a regulatory directive requires termination of the account relationship.
Where an account is restricted or closed for compliance reasons, any remaining balance is handled in accordance with applicable legal requirements and internal procedures.
9. Player Obligations
By registering and maintaining an account with Chilliwack, each account holder agrees to:
- Provide accurate, complete, and current information at registration and upon request.
- Cooperate with identity verification and source-of-funds requests in a timely manner.
- Notify Chilliwack of any changes to personal information that affect the accuracy of records held.
- Refrain from using the account in a manner that facilitates money laundering, terrorist financing, or any other financial crime.
10. Policy Updates
This policy is reviewed and updated as required to reflect changes in applicable legislation, regulatory guidance, or internal compliance standards. The current version of this policy governs all accounts and transactions at the time of access. Continued use of Chilliwack services following any update constitutes acceptance of the revised policy.