AML/KYC Policy
1. Introduction and Scope
This policy outlines the anti-money laundering (AML) and know-your-customer (KYC) requirements applicable to Club Regent Casino at 1425 Regent Avenue West, Winnipeg, Manitoba. Club Regent Casino is owned and operated by Manitoba Liquor & Lotteries Corporation (MBLL), which serves as the sole reporting entity to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) for all Manitoba casino operations.
All individuals accessing gaming services at Club Regent Casino are subject to these rules. Adherence is mandatory under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related regulations.
2. Regulatory Framework
Club Regent Casino operates within the framework of federal AML legislation administered by FINTRAC and under provincial oversight by the Liquor, Gaming and Cannabis Authority of Manitoba (LGCA). MBLL maintains an AML compliance program that is subject to internal and external audits, including those by FINTRAC.
The AML requirements apply to Club Regent Casino, McPhillips Station Casino, and the MBLL video lottery terminal network. MBLL manages all AML-related identification, reporting, and record-keeping obligations at Club Regent Casino.
3. Customer Identification Requirements
3.1. Entry Identification
Patrons must be of legal gambling age to enter Club Regent Casino. Security personnel may require identification at entry to confirm age or to enforce restrictions such as self-exclusion or bans.
3.2. Transaction-Based Identification
Identification and personal information must be collected when any of the following occur:
– Winning single or accumulated jackpots of 10,000 CAD or more within a 24-hour period
– Redeeming 10,000 CAD or more in chips or slot tickets for cash, cheque, or both within 24 hours
– Purchasing 10,000 CAD or more in chips or slot tickets within 24 hours
– Purchasing 3,000 CAD or more in chips or slot tickets in a single transaction
– Currency exchanges of 3,000 CAD or more
– Any transaction deemed suspicious, regardless of amount
Identification may be requested at lower thresholds if necessary for regulatory compliance.
3.3. Acceptable Identification
Acceptable identification for AML purposes includes:
– Driver’s licence (Manitoba or other jurisdiction)
– Provincial or territorial government-issued identification card
– Passport
– Secure certificate of Indian Status
– Permanent resident card
Other forms may be accepted at management’s discretion.
3.4. Unacceptable Identification
The following are not accepted for AML identification:
– Expired identification
– Identification that appears altered or is inconsistent with the person
– Manitoba Liquor Control Commission age-of-majority cards
– Provincial health cards
– Canadian citizenship cards without expiry dates or issued several years ago
4. Information Collection
Upon identification request, MBLL collects:
– Full legal name
– Full residential address
– Date of birth
– Type, number, and expiry date of identification
– Occupation or business
– Telephone number
– Email address
– Country of residence
– Other names or aliases (if applicable)
– Name of employer or place of employment
– Source of cash (where applicable)
If more than one individual is involved in a reportable transaction, each person must provide full identification and occupation information.
5. Reporting Obligations
5.1. Casino Disbursement Reports
MBLL submits Casino Disbursement Reports to FINTRAC for disbursements of 10,000 CAD or more, whether as a single transaction or multiple disbursements within 24 hours to or on behalf of the same person or entity. Reports are filed electronically within 15 calendar days.
5.2. Suspicious Transaction Reports
Suspicious transactions, regardless of the amount, are reported to FINTRAC if there are reasonable grounds to suspect a connection to money laundering or terrorist financing.
5.3. Confidentiality of Reports
Patrons will not be informed if reports are filed. Disclosure of such reporting is prohibited.
6. Consequences of Non-Compliance by Patrons
Patrons who refuse to provide required identification or details may be subject to:
– Refusal of transaction
– Refusal of service
– Removal from the premises
– Withholding of large jackpot payments
– Ban from Club Regent Casino and Casinos of Winnipeg properties
These actions support compliance with federal AML requirements and are applied without exception.
7. Privacy and Data Protection
Personal information collected is used only for AML compliance, regulatory reporting, and purposes permitted by law. Privacy practices are governed by legislation and the MBLL privacy notice.
Questions or complaints regarding personal information may be directed to MBLL’s Privacy Coordinator at [email protected] or by mail to Manitoba Liquor & Lotteries, Buffalo Place, Winnipeg, Manitoba. Complaints may also be submitted to the Office of the Manitoba Ombudsman.
8. Security and Monitoring
Club Regent Casino enforces identification and monitors activities through security personnel and surveillance systems. Security officers are authorized to:
– Verify and validate identification
– Monitor guests for intoxication, exclusion, or suspicious activity
– Inspect bags and parcels on the casino floor
– Collaborate with surveillance teams
– Escort patrons, employees, and authorized persons as needed
All activities are in accordance with applicable laws and MBLL policies.
9. Prohibited Online Services
Club Regent Casino does not offer online gaming or mobile application services. Any website, app, or social media post claiming to provide Club Regent Casino online gambling is fraudulent and not affiliated with MBLL. Such services do not provide AML/KYC safeguards or regulatory oversight.
10. Contact Information
For questions regarding this AML/KYC policy, contact Manitoba Liquor & Lotteries Corporation via the official Casinos of Winnipeg website at casinosofwinnipeg.com or through MBLL’s Communications and Corporate Affairs department.
This policy may be amended to reflect changes in law, FINTRAC guidance, or updates to MBLL compliance programs.