Record keeping requirements for casinos


March 2021

This guidance comes into effect on June 1, 2021.

Casinos have record keeping requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations.

This guidance outlines certain record keeping requirements for casinos. You have additional record keeping requirements that are detailed in the following guidance:

This guidance answers the following questions:

  1. What records must I keep and what must they contain?
  2. What are my responsibilities when maintaining records?
  3. What are the exceptions to the record keeping requirements?

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

1. What records must I keep and what must they contain?

You must keep the following records:

  1. Reports — a copy of every report sent to FINTRAC
    • Suspicious Transaction Reports
    • Terrorist Property Reports
    • Large Cash Transaction Reports
    • Large Virtual Currency Transaction Reports
    • Casino Disbursement Reports
    • Electronic Funds Transfer Reports
  2. Large cash transaction records
  3. Large virtual currency transaction records
  4. Records of electronic funds transfers of $1,000 or more
  5. Receipt of funds records of $3,000 or more
  6. Foreign currency exchange transaction tickets
  7. Records of credit extension of $3,000 or more
  8. Account records
    • Records for account holders and persons authorized to give instructions
    • Signature cards
    • Intended use of an account
    • Applications
    • Account operating agreements
    • Deposit slips
    • Debit and credit memos

**Note: When you are required to keep records about clients, you should be as descriptive as possible. Being descriptive when recording the nature of the principal business or occupation of a client will help determine whether a transaction or activity is consistent with what would be expected for that client. For example, when the client's occupation is "manager", the record should reflect the area of management, such as "hotel reservations manager" or "retail clothing store manager". When an entity's principal business area is "sales", the record should specify the type of sales, such as "pharmaceutical sales" or "retail sales".

a. Reports — a copy of every report sent to FINTRAC

You must keep a copy of every report that you submit to FINTRAC as a record.

Suspicious Transaction Reports

When you submit a Suspicious Transaction Report (STR) to FINTRAC, you must keep a copy of it.Footnote 1

Retention: At least five years after the day the STR was submitted.Footnote 2

Terrorist Property Reports

When you submit a Terrorist Property Report (TPR) to FINTRAC, you must keep a copy of it.Footnote 3

Retention: At least five years after the day the TPR was submitted.Footnote 4

Large Cash Transaction Reports

When you submit a Large Cash Transaction Report (LCTR) to FINTRAC, you must keep a copy of it.Footnote 5

Retention: At least five years from the date the LCTR was created.Footnote 6

Large Virtual Currency Transaction Reports

When you submit a Large Virtual Currency Transaction Report (LVCTR) to FINTRAC, you must keep a copy of it.Footnote 7

Retention: At least five years from the date the LVCTR was created.Footnote 8

Casino Disbursement Reports

When you submit a Casino Disbursement Report (CDR) to FINTRAC, you must keep a copy of it.Footnote 9

Retention: At least five years from the date the CDR was created.Footnote 10

Electronic Funds Transfer Reports

When you submit an Electronic Funds Transfer Report (EFTR) to FINTRAC, you must keep a copy of it.Footnote 11

Retention: At least five years from the date the EFTR was created.Footnote 12

b. Large cash transaction records

You must keep a large cash transaction record when you receive $10,000 or more in cash.Footnote 13

Large cash transactions include the receipt of $10,000 or more in cash for the following transactions:Footnote 14

If you authorize a person or an entity to receive funds on your behalf, and that person or entity receives $10,000 or more in cash in accordance with the authorization, you are deemed to have received the amount when it is received by the person or entity, and you must keep a large cash transaction record.Footnote 15

**Note: This obligation is subject to the 24-hour rule.Footnote 16

A large cash transaction record must include:Footnote 17

Retention: At least five years from the date the large cash transaction record was created.Footnote 18

c. Large virtual currency transaction records

You must keep a large virtual currency (VC) transaction record when you receive VC in an amount equivalent to $10,000 or more.Footnote 19

If you authorize a person or an entity to receive VC on your behalf, and that person or entity receives VC in an amount equivalent to $10,000 or more in accordance with the authorization, you are deemed to have received the VC when it is received by the person or entity, and you must keep a large VC transaction record.Footnote 20

**Note: This obligation is subject to the 24-hour rule.Footnote 21

A large VC transaction record must include:Footnote 22

Retention: At least five years from the date the large virtual currency transaction record was created.Footnote 23

d. Records of electronic funds transfers of $1,000 or more

Initiating an EFT of $1,000 or more

When you initiate, at the request of a person or entity, an electronic funds transfer (EFT) of $1,000 or more, you must record:Footnote 24

Sending an international EFT of $1,000 or more

When you send, as an intermediary, an international EFT of $1,000 or more that was initiated by another reporting entity, you must record:Footnote 25

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

When you are the final recipient of an international EFT of $1,000 or more, you must record:Footnote 26

**Note: International EFTs and EFTs within Canada sent via a SWIFT MT-103 message or equivalent are subject to the travel rule.Footnote 27 Please see FINTRAC's Travel rule guidance for more information.

Retention: At least five years from the date the EFT record was created.Footnote 28

e. Receipt of funds record of $3,000 or more

When you receive $3,000 or more in funds in a single transaction, you must keep a record that indicates the receipt of funds and includes:Footnote 29

Retention: At least five years from the date the receipt of funds record was created.Footnote 30

f. Foreign currency exchange transaction tickets

You must keep a foreign currency exchange transaction ticket, which may take the form of an entry in a transaction register, for every foreign currency exchange transaction you conduct, regardless of the amount.Footnote 31 Each transaction ticket must include:Footnote 32

Retention: At least five years from the date the foreign exchange transaction record was created.Footnote 33

g. Records of credit extension of $3,000 or more

When you extend credit to a client for $3,000 or more, you must keep a record of:Footnote 34

Retention: At least five years from the date the record of credit extension was created.Footnote 35

h. Account records

For every account opened for a client, you must keep the following records: 

Records for account holders and persons authorized to give instructions

You must keep a record for every account holder (person, corporation or other entity) and for every other person who is authorized to give instructions in respect of the account.

For a person, the record must include their name, address, telephone number, date of birth, and their occupation, or in the case of a sole proprietor, the nature of their principal business.Footnote 36

For an account holder that is a corporation or an entity other than a corporation, the record must include its name, address, telephone number, and the nature of its principal business.Footnote 37

For a corporation, you must also keep a copy of the part of its official corporate records that contains any provision relating to the power to bind the corporation regarding the account or a transaction.Footnote 38 This could be found in, for example:

Retention: At least five years from the date the record was created. However, if this information is kept in one of the other account records, then the retention of that other record applies – at least five years from the date the account is closed.Footnote 39

Signature cards

You must keep a signature card for every person authorized to give instructions on an account you open.Footnote 40 It can include a person's handwritten signature or an electronic signature that was created or adopted by the person.Footnote 41

An electronic signature can be numeric, character-based, or biometric, so long as it is unique to the person and a record can be kept. An electronic signature may also be encrypted. For example, a client's personal identification number (PIN) can be used as an electronic signature. FINTRAC's expectation is that it will be able to review a signature card record during an examination, but the electronic signature does not need to be unencrypted.

You can keep a single signature card for a client that holds multiple accounts. You do not need to create a new signature card every time they open a subsequent account.

Retention: At least five years from the date the account was closed.Footnote 42

Intended use of an account

You must keep a record of the intended use of an account.Footnote 43

Retention: At least five years from the date the account was closed.Footnote 44

Applications

You must keep a record of every application in respect of an account.Footnote 45

Retention: At least five years from the date the account was closed.Footnote 46

Account operating agreements

You must keep a record of every account operating agreement that you create or receive in respect of an account.Footnote 47 An account operating agreement is a document that outlines the agreement between you and your client about the account's operation.

Retention: At least five years from the date the account was closed.Footnote 48

Deposit slips

You must keep a deposit slip for every deposit to an account.Footnote 49 A deposit slip means a record that includes:Footnote 50

Retention: At least five years from the date the deposit slip was created.Footnote 51

Debit and credit memos

You must keep every debit and credit memo that you create or receive regarding an account.Footnote 52

Retention: At least five years from the date the debit or credit memo was created.Footnote 53

2. What are my responsibilities when maintaining records?

In order to comply with your record keeping requirements, you must keep records in such a manner that they can be provided to FINTRAC within 30 days of a request.Footnote 54 The records may also be requested through a judicial order by law enforcement to support an investigation of money laundering or terrorist activity financing. A record (or a copy) may be kept in a machine-readable or electronic form, so long as a paper copy can easily be produced.Footnote 55

Employees who keep records for you are not required to keep them after their employment ends. The same is true for persons in a contractual relationship with you, when the contractual relationship ends, they no longer have to keep records for you.Footnote 56 You have to obtain and keep the records that were kept for you by an employee or a contractor before the end of the person's employment or contract.

There may be situations where you are required to keep records for purposes other than complying with your obligations under the PCMLTFA. For example, a federal or provincial regulator may require you to keep records in addition to those described in this guidance. If this is the case, you must still meet the requirements described in this guidance. For example, the retention period for your records can be longer than what is described, but it cannot be shorter.

3. What are the exceptions to the record keeping requirements?

If you are required to keep a record with information that is readily available in other records, you do not have to record the information again.Footnote 57

For example, when you keep a copy of a large cash transaction report (LCTR) you may choose to use this as your large cash transaction record for the same transaction, so long as all of the information that would otherwise be kept in the large cash transaction record is captured within the report. Any requirement related to keeping the large cash transaction record would still apply, such as verifying identity.

Financial entities, public bodies, and very large corporations or trusts

You are not required to keep a receipt of funds record, a large cash transaction record, or a large VC transaction record if the funds, cash or VC is received from a client that is a financial entity (FE) or a public body, or from a person who is acting on behalf of a client that is an FE or public body.Footnote 58

You are not required to keep the records identified in this guidance for EFTs, foreign currency exchange transactions, extensions of credit, receipt of funds, and account records, when you open an account for, or a transaction is conducted by: Footnote 59

Virtual currency

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 a different transaction or a transfer of information, you are not required to keep a large VC transaction record.Footnote 60

Date Modified: