South Beach Casino AML and KYC Policy

1. Introduction and Regulatory Framework

South Beach Casino & Resort is a land-based casino located at 1 Ocean Drive, Scanterbury, Manitoba, R0E 1W0, Canada, on the Brokenhead Ojibway Nation Reserve. As a casino operating within the province of Manitoba, South Beach Casino is subject to federal and provincial regulatory requirements governing anti-money laundering (AML) and know your customer (KYC) obligations.

At the federal level, operations are carried out in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the associated regulations administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). At the provincial level, the casino is regulated by the Liquor, Gaming and Cannabis Authority of Manitoba (LGCA), which oversees licensing and regulatory compliance for gaming operations in Manitoba.

This document describes the identity verification obligations, transaction reporting requirements, recordkeeping standards, and related compliance procedures that apply to operations at South Beach Casino.

2. Purpose of This Policy

This policy establishes the framework under which South Beach Casino identifies clients, monitors transactions, and reports specified financial activity to FINTRAC in accordance with Canadian law. The purpose of these measures is to detect, deter, and prevent money laundering, terrorist financing, and other financial crimes within casino operations.

3. Identity Verification Obligations

3.1 When Identity Verification Is Required

South Beach Casino is required to verify the identity of clients in the following circumstances, as prescribed by FINTRAC guidance for casinos:

• Large cash transactions: when a client conducts a cash transaction of CAD 10,000 or more in a single transaction or in two or more transactions totaling CAD 10,000 or more within a 24-hour period.
• Large virtual currency transactions: when a client conducts a virtual currency transaction of CAD 10,000 or more.
• Casino disbursements: when South Beach Casino disburses funds of CAD 10,000 or more to a client.
• Extension of credit: when credit of CAD 3,000 or more is extended to a client.
• Receipt of funds: when funds of CAD 3,000 or more are received from a client.
• Foreign currency exchange: when a foreign currency exchange transaction of CAD 3,000 or more is conducted.
• Electronic funds transfers (EFTs): when an EFT of CAD 1,000 or more is initiated or received on behalf of a client.
• Suspicious transactions: regardless of the amount, when there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing.
• Account opening: when a client opens a casino account.

3.2 Exemptions from Identity Verification

In certain circumstances, identity verification is not required even when the above thresholds are met. These exemptions apply when:

• Funds are received from a financial entity or public body in the context of a large cash transaction.
• The transaction involves a deposit to a business account or an automated banking machine.
• A large virtual currency transaction involves the validation of a distributed ledger transaction or a nominal amount used solely for the purpose of validating another transaction.
• Funds of CAD 3,000 or more are received from a financial entity or public body in the context of an EFT or receipt of funds.

These exemptions are applied in accordance with FINTRAC guidance and do not override the casino’s obligation to assess and document the basis for any exemption applied.

4. Acceptable Identification Documents

When identity verification is required, South Beach Casino collects and reviews government-issued identification documents. Acceptable documents include, but are not limited to:

• Valid Canadian passport
• Provincial or territorial driver’s licence
• Provincial or territorial identification card
• Permanent resident card
• Canadian citizenship certificate with photograph

Documents must be current, unaltered, and issued by a recognized government authority. South Beach Casino may request additional documentation where the primary document does not provide sufficient information to complete verification.

5. Customer Due Diligence

5.1 Standard Due Diligence

Standard customer due diligence (CDD) is applied to all clients subject to identity verification requirements. This process includes collecting the client’s full legal name, date of birth, address, and the nature of the transaction or account relationship.

5.2 Enhanced Due Diligence

Enhanced due diligence (EDD) is applied in circumstances where a client or transaction presents a higher risk of money laundering or terrorist financing. Factors that may trigger EDD include, but are not limited to:

• Transactions that are unusually large or complex without apparent lawful purpose.
• Clients identified as politically exposed persons (PEPs) or their associates.
• Transactions involving jurisdictions identified as high-risk by FINTRAC or the Financial Action Task Force (FATF).
• Patterns of activity inconsistent with a client’s known profile.

Under EDD, South Beach Casino may request additional documentation, conduct further background checks, and apply additional scrutiny to the source of funds.

6. Transaction Monitoring and Reporting

South Beach Casino maintains ongoing monitoring of client transactions to identify activity that may indicate money laundering, terrorist financing, or other financial crime. Monitoring is conducted on a risk-sensitive basis.

The following reports are filed with FINTRAC as required by law:

• Large Cash Transaction Report (LCTR): cash transactions of CAD 10,000 or more within 24 hours.
• Large Virtual Currency Transaction Report (LVCTR): virtual currency transactions of CAD 10,000 or more.
• Suspicious Transaction Report (STR): any transaction where there are reasonable grounds to suspect money laundering or terrorist financing, regardless of amount.
• Casino Disbursement Report (CDR): disbursements of CAD 10,000 or more to a client.

Reports are submitted to FINTRAC within the timeframes prescribed by the PCMLTFA and its regulations.

7. Recordkeeping

South Beach Casino retains records related to identity verification, transactions, and compliance activities for a minimum of five years from the date the record was created, as required under the PCMLTFA. Records are maintained in a manner that allows for timely retrieval upon request by FINTRAC or other authorized regulatory authorities.

8. Privacy and Data Handling

Personal information collected for AML and KYC purposes is handled in accordance with South Beach Casino’s Privacy Policy, available at southbeachcasino.ca/privacy-policy. Clients may direct inquiries regarding the collection, use, or correction of personal information to the Privacy Officer at the address, telephone, or email contacts listed in Section 10 of this document.

Personal information collected for compliance purposes is used solely for the purposes of identity verification, transaction monitoring, regulatory reporting, and recordkeeping as required by applicable law. Such information is not used for marketing and is not shared with third parties except as required by law or authorized by the client.

9. Non-Compliance and Refusal of Service

South Beach Casino reserves the right to refuse to process a transaction, provide a service, or continue a business relationship where a client fails or refuses to provide required identification or information, or where there are reasonable grounds to suspect that proceeding would result in a breach of applicable AML or KYC obligations.

Where a suspicious transaction report is filed, South Beach Casino is prohibited by law from disclosing to the client or any other person that a report has been or will be made to FINTRAC.

10. Contact Information

Inquiries regarding this policy or related compliance matters may be directed to South Beach Casino & Resort using the following contact details:

South Beach Casino & Resort
1 Ocean Drive (Box 777)
Scanterbury, Manitoba, R0E 1W0
Canada

Telephone: +1-204-766-2100
Toll-free: 1-877-775-8259
Email: [email protected]
Website: southbeachcasino.ca

This policy is subject to review and amendment in accordance with changes to applicable legislation, FINTRAC guidance, or LGCA requirements. Clients are advised to consult the current policy as published by South Beach Casino.