1. Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by High Roller Casino to all accounts held by Canadian players. The policy establishes the obligations of the company and its account holders with respect to identity verification, source of funds documentation, transaction monitoring, and regulatory reporting.
These measures are not optional. They constitute a regulatory requirement applicable to High Roller Casino as a licensed online gambling operator serving Canadian players. Compliance with this policy is a condition of account access and continued use of the platform.
2. Legal Framework
High Roller Casino operates in accordance with Canadian federal law governing anti-money laundering and counter-terrorist financing. The primary legislative instrument is the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Oversight and enforcement of obligations under this Act is carried out by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
For players located in Ontario, additional requirements apply under the standards set by the Alcohol and Gaming Commission of Ontario (AGCO) and iGaming Ontario. High Roller Casino has established a dedicated AML compliance program for its Ontario operations, including a partnership with a third-party risk management and AML technology provider to support transaction monitoring and case management in that province.
All KYC and AML procedures applied by High Roller Casino are consistent with FINTRAC casino guidance and applicable provincial requirements.
3. Identity Verification Requirements
3.1 When Verification Is Required
High Roller Casino is required to verify the identity of account holders in the following circumstances:
- At the time of account registration
- Before processing any withdrawal
- Upon receipt of cash or virtual currency equivalent to CAD 10,000 or more in a single transaction
- Upon initiation or receipt of an electronic funds transfer (EFT) of CAD 1,000 or more
- Upon extension of credit of CAD 3,000 or more
- Upon receipt of funds of CAD 3,000 or more
- Upon foreign currency exchange transactions of CAD 3,000 or more
- In connection with any casino disbursement
- In connection with any transaction identified as suspicious, regardless of amount
3.2 Documents Accepted for Identity Verification
To satisfy KYC requirements, account holders must submit the following:
- Government-issued identity document: a valid passport, national identity card, or driver’s licence bearing the holder’s photograph and full legal name
- Proof of residence in Canada: a recent utility bill, bank statement, or official correspondence issued within the last three months, showing the account holder’s name and residential address
Where applicable, High Roller Casino may also require documentation confirming the origin of funds used for gambling activity. This requirement applies in particular to large deposits, high-value withdrawals, and accounts identified as elevated risk.
3.3 Minimum Age Requirement
Account holders must be of legal gambling age in their province of residence. For players in Ontario, the minimum age for real-money gaming is 19 years. Identity verification is used to confirm that this requirement is met before any real-money activity is permitted.
4. Source of Funds and Source of Wealth
4.1 Source of Funds
High Roller Casino may request documentation confirming the source of funds used for deposits where a transaction meets or exceeds applicable thresholds or where the account presents risk indicators. Acceptable documentation includes bank statements, payroll records, or other financial records demonstrating the legitimate origin of the funds.
4.2 Source of Wealth
For high-value withdrawals or accounts associated with sustained high-volume activity, High Roller Casino may require documentation confirming the broader source of wealth of the account holder. This may include business ownership records, investment account statements, or other financial documentation.
Failure to provide requested source of funds or source of wealth documentation within the timeframe specified by High Roller Casino may result in suspension of withdrawal processing or account restriction pending review.
5. Transaction Monitoring and Reporting
High Roller Casino maintains a real-time transaction monitoring program designed to identify patterns or transactions that may indicate money laundering, terrorist financing, or other financial crime.
High Roller Casino is required to file the following reports with FINTRAC:
- Large Cash Transaction Reports (LCTRs): filed for any receipt of CAD 10,000 or more in cash in a single transaction or over the course of a gaming session
- Suspicious Transaction Reports (STRs): filed for any transaction suspected of being linked to criminal activity, regardless of the amount involved
- Casino Disbursement Reports: filed in connection with disbursements as defined under FINTRAC casino guidance
These reporting obligations are mandatory and are carried out regardless of whether the account holder has been notified.
6. Enhanced Due Diligence
High Roller Casino applies enhanced due diligence procedures to account holders who present elevated risk indicators. These include, but are not limited to:
- Accounts associated with large or frequent cash-equivalent transactions
- Accounts held by politically exposed persons (PEPs) or their close associates
- Accounts where the source of funds or source of wealth cannot be readily established
- Accounts exhibiting unusual transaction patterns inconsistent with stated activity
- Non-resident account holders or accounts involving foreign-sourced funds
Enhanced due diligence may involve additional document requests, extended review periods, temporary holds on withdrawals, or escalation to compliance personnel. In cases where unusual or suspicious activity cannot be resolved through standard procedures, High Roller Casino may request video verification or direct communication with the account holder.
7. Record Retention
High Roller Casino retains all identity verification records, transaction records, and compliance documentation for a minimum of five years from the date of the relevant transaction or the closure of the account, whichever is later. This retention period is consistent with FINTRAC requirements under the PCMLTFA.
8. Screening Obligations
All account holders are screened against applicable sanctions lists and databases of politically exposed persons prior to account activation and on an ongoing basis. Accounts identified as matching a sanctioned individual or entity will be restricted pending review and reported to the relevant authority as required by law.
9. Account Holder Obligations
By opening and maintaining an account with High Roller Casino, account holders agree to:
- Provide accurate and complete identity information at registration and upon request
- Submit required verification documents within the timeframe specified
- Notify High Roller Casino of any material change to their personal or financial circumstances that may affect their account status
- Cooperate with any compliance review or enhanced due diligence process initiated by High Roller Casino
Provision of false, incomplete, or misleading information in connection with identity verification or source of funds documentation constitutes a breach of account terms and may result in permanent account closure and reporting to relevant authorities.
10. Policy Updates
This policy is reviewed periodically to reflect changes in applicable law, regulatory guidance, and internal compliance standards. The current version of this policy governs all active accounts. Continued use of an account following any update to this policy constitutes acceptance of the revised terms.