When to verify the identity of persons and entities—Casinos


March 2021

This guidance comes into effect on June 1, 2021.

This guidance on client identification describes when casinos must verify the identity of persons and entities as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations. Details on how to verify the identity of persons and entities are available in FINTRAC's Methods to verify the identity of persons and entities guidance.

This document answers the following questions:

  1. When do I have to verify the identity of persons and entities?
  2. What is the difference between verifying identity and keeping client identification information up to date?
  3. What are the exceptions to client identification requirements?

**Note: Throughout this guidance, references to dollar amounts (such as $10,000) are in Canadian dollars.

1. When do I have to verify the identity of persons and entities?

As a casino, you must verify the identity of clients for the following:

  1. Large cash transactions
  2. Large virtual currency transactions
  3. Suspicious transactions
  4. Casino disbursements
  5. Extension of credit of $3,000 or more
  6. Receipt of funds of $3,000 or more
  7. Foreign currency exchange transactions of $3,000 or more
  8. Initiation of an electronic funds transfer (EFT) of $1,000 or more
  9. Final receipt of an international EFT of $1,000 or more
  10. Accounts—Account holders and persons authorized to give instructions

a. Large cash transactions

You must verify the identity of every person or entity from which you receive $10,000 or more in cash when the transaction takes place.Footnote 1 This includes a situation where you are deemed to have received cash because you have authorized another person or entity to receive it on your behalf.Footnote 2

Large cash transactions include the receipt of $10,000 or more in cash for the following transactions:Footnote 3

**Note: This obligation is subject to the 24-hour rule.Footnote 4

b. Large virtual currency transactions

You must verify the identity of every person or entity from which you receive virtual currency (VC) in an amount equivalent to $10,000 or more when the transaction takes place.Footnote 5 This includes a situation where you are deemed to have received VC because you have authorized another person or entity to receive it on your behalf.Footnote 6

**Note: This obligation is subject to the 24-hour rule.Footnote 7

c. Suspicious transactions

You must take reasonable measures to verify the identity of every person or entity that conducts or attempts to conduct a suspicious transaction, regardless of the transaction amount, and including transactions that would normally be exempt from client identification requirements, before sending a Suspicious Transaction Report (STR).Footnote 8

d. Casino disbursements

You must verify the identity of every person who receives a casino disbursement of $10,000 or more, for which a Casino Disbursement Report (CDR) is required, when the transaction takes place.Footnote 9

**Note: This obligation is subject to the 24-hour rule.Footnote 10

e. Extension of credit of $3,000 or more

You must verify the identity of every person who conducts a transaction for which the casino extends credit of $3,000 or more to a person or entity, when the transaction takes place.Footnote 11

f. Receipt of funds of $3,000 or more

You must verify the identity of every person who conducts a transaction in which you receive $3,000 or more in funds when the transaction takes place.Footnote 12

g. Foreign currency exchange of $3,000 or more

You must verify the identity of every person who requests a foreign currency exchange of $3,000 or more when the transaction takes place.Footnote 13

h. Initiation of an electronic funds transfer (EFT) of $1,000 or more

You must verify the identity of every person who requests the initiation of an EFT of $1,000 or more for a person or entity, when the transaction is being requestedFootnote 14

**Note: The initiation of an international EFT is subject to the 24-hour rule.Footnote 15

i. Final receipt of an international EFT of $1,000 or more

You must verify the identity of every person who is the beneficiary of an international EFT of $1,000 or more that you finally receive, when the transaction takes place.Footnote 16

**Note: The final receipt of an EFT is subject to the 24-hour rule.Footnote 17

j. Accounts—Account holders and persons authorized to give instructions

Account holders

You must verify the identity of every person for whom you open an account before any funds are disbursed.Footnote 18 You must also verify the identity of every corporation and other entity for which you open an account before the first transaction, other than an initial deposit, is carried out on the account.Footnote 19

You cannot open an account for a person, corporation, or other entity if you cannot verify their identity in accordance with the regulations.Footnote 20

Persons authorized to give instructions

You must verify the identity of every person authorized to give instructions on an account that you open before any funds are disbursed.Footnote 21

2. What is the difference between verifying identity and keeping client identification information up to date?

As a part of your ongoing monitoring requirements for business relationships, you must keep client identification information up to date, at a frequency that will vary based on your risk assessment, and as outlined in your policies and procedures.Footnote 22 This does not require you to re-identify clients in accordance with the methods to verify identity. As explained in the ongoing monitoring guidance, the requirement is only for you to keep client identification information up to date. This is understood to be information that you have about your client such as their name and address. In the case of a person, this would also include, but is not limited to, the nature of their principal business or their occupation; and in the case of an entity, the nature of its principal business.

3. What are the exceptions to client identification requirements?

You do not have to re-identify a person or an entity if you previously did so using the methods specified by the Regulations in place at the time, and kept the associated records, so long as you have no doubts about the information used.Footnote 23

Large cash transactions

You do not have to verify the identity of a person or entity that conducts a large cash transaction if:

Large VC transactions

You do not have to verify the identity of a person or entity that conducts a large VC transaction if you receive the VC from a client that is an FE or a public body, or from a person acting on behalf of a client that is an FE or public body.Footnote 26

When you receive VC as compensation for the validation of a transaction that is recorded in a distributed ledger or you receive a nominal amount of VC for the sole purpose of validating another transaction or a transfer of information—you do not need to keep a large VC transaction record and do not need to verify identity.Footnote 27

Suspicious transactions

You do not have to take reasonable measures to verify the identity of the person or entity that conducts or attempts to conduct a suspicious transaction if:

Receipt of funds of $3,000 or more

You do not have to verify the identity of a person who conducts a transaction in which you receive $3,000 or more in funds if you receive the funds from an FE or a public body or from a person acting on behalf of a client that is an FE or public body.Footnote 30

Public bodies, very large corporations and trusts

You do not have to verify the identity of a person or entity when you undertake the following activities for a public body or very large corporation or trust, or a subsidiary of either of those types of entities, if the financial statements of the subsidiary are consolidated with those of the public body, or very large corporation or trust:Footnote 31

Account openings

You do not have to verify the identity of a person who opens an account, in the following circumstances:Footnote 32

Date Modified: