Sunrise Casino

This document outlines the AML and KYC obligations applicable to Sunrise Casino accounts in Canada.

Sunrise Casino AML / KYC Policy

  1. Introduction and Scope

This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy of Sunrise Casino as it applies to all registered accounts and transactions conducted through the platform by persons located in Canada. The policy is established in accordance with Canada’s federal anti-money laundering and anti-terrorist financing framework, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations, as well as guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

Sunrise Casino operates as a reporting entity under the PCMLTFA. As such, the company is legally required to implement and maintain a documented, risk-based AML and anti-terrorist financing (ATF) compliance program. This policy applies to all customers, account holders, and any persons conducting transactions with Sunrise Casino.

  1. Purpose of This Policy

The purpose of this policy is to:

  • Define the obligations of Sunrise Casino under Canadian AML and KYC law.
  • Establish the procedures by which customer identities are verified.
  • Describe the conditions under which transactions are monitored and reported.
  • Outline the rights and obligations of customers in relation to identity verification and compliance.
  • Specify record retention requirements and data handling procedures.
  1. Regulatory Framework

Sunrise Casino’s AML and KYC obligations are governed primarily by the following:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
  • FINTRAC guidance for casinos, including the casino-specific client identification guidance that took effect on June 1, 2021
  • Applicable provincial gambling authority requirements

Casinos are classified as designated reporting entities under the PCMLTFA. This classification imposes mandatory obligations with respect to customer identification, transaction monitoring, suspicious activity reporting, and record retention.

  1. Know Your Customer (KYC) Procedures

4.1 Identity Verification Triggers

Sunrise Casino is required to verify the identity of a customer when any of the following events occur:

  • Receipt of cash in the amount of CAD 10,000 or more from a single person or entity.
  • Receipt of virtual currency in an amount equivalent to CAD 10,000 or more.
  • A casino disbursement of CAD 10,000 or more.
  • Extension of credit in the amount of CAD 3,000 or more.
  • Receipt of funds in the amount of CAD 3,000 or more.
  • Initiation of a suspicious transaction, regardless of amount.
  • Foreign currency exchange transactions meeting applicable thresholds.

Identity verification must be completed before gambling activity takes place where required by applicable FINTRAC guidance.

4.2 Acceptable Identification Documents

To satisfy KYC requirements, customers are required to provide valid, government-issued identification. Acceptable documents include:

  • Valid passport
  • Government-issued driver’s licence with photograph
  • Provincial or territorial identification card with photograph
  • Permanent resident card or equivalent government-issued document

Documents must be current, unaltered, and issued by a recognized government authority. Sunrise Casino reserves the right to request additional documentation where the initial submission is insufficient to confirm identity or where doubts arise regarding the accuracy of existing information.

4.3 Information Collected

During the KYC process, Sunrise Casino collects at a minimum the following customer information:

  • Full legal name
  • Date of birth
  • Residential address
  • Government-issued identification number and document type

This information is verified against the submitted documentation and, where applicable, against third-party verification sources.

4.4 Re-Identification and Exceptions

Where a customer has previously been identified using prescribed methods and records have been retained in accordance with this policy, Sunrise Casino is not required to re-verify identity provided there is no doubt about the accuracy or completeness of the existing information. Specific exceptions also apply in the following circumstances:

  • A person already holds an account and opens a subsequent account under the same identity.
  • A person is authorized on a business account and at least three persons authorized to give instructions on that account have already been verified.

These exceptions are applied in accordance with FINTRAC guidance and do not override the obligation to verify identity where a triggering event occurs.

  1. Customer Due Diligence and Risk Assessment

Sunrise Casino applies a risk-based approach to customer due diligence. All customers are assessed at the point of onboarding and on an ongoing basis. Risk factors considered include, but are not limited to:

  • Source of funds and consistency with the customer’s financial profile.
  • Transaction patterns relative to the stated purpose of the account.
  • Geographic indicators and geolocation consistency.
  • Politically Exposed Person (PEP) status.
  • Sanctions list screening results.
  • Adverse media and other reputational risk indicators.

Customers identified as higher risk are subject to enhanced due diligence (EDD). Enhanced due diligence may include requests for additional documentation, source of wealth declarations, or increased monitoring frequency.

5.1 Politically Exposed Persons (PEPs)

Sunrise Casino screens customers against PEP lists at onboarding and on a periodic basis thereafter. Customers identified as PEPs, or as close associates or family members of PEPs, are subject to enhanced due diligence procedures and senior management approval prior to account activation or continuation.

5.2 Sanctions Screening

All customers are screened against applicable sanctions lists, including those maintained by the Government of Canada and relevant international bodies. Accounts associated with sanctioned individuals or entities will not be activated or will be suspended pending further review.

  1. Transaction Monitoring and Reporting

6.1 Large Cash Transaction Reports (LCTRs)

Sunrise Casino is required to file a Large Cash Transaction Report with FINTRAC upon receipt of CAD 10,000 or more in cash from a single person or entity in a single transaction or in two or more transactions totaling CAD 10,000 or more within a 24-hour period.

6.2 Suspicious Transaction Reports (STRs)

Where Sunrise Casino has reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, a Suspicious Transaction Report must be filed with FINTRAC. This obligation applies regardless of the amount involved and regardless of whether the transaction was completed.

Indicators that may trigger an STR include, but are not limited to:

  • Structuring of deposits or withdrawals to avoid reporting thresholds.
  • Significant deposits followed by immediate withdrawal with minimal gaming activity.
  • Use of multiple accounts under different identities.
  • Inconsistency between funding details and player registration information.
  • Use of false, forged, or altered identification documents.
  • Transactions inconsistent with the customer’s known financial profile.
  • Adverse media linking a customer to criminal activity.

6.3 Large Virtual Currency Transaction Reports

Where Sunrise Casino receives virtual currency equivalent to CAD 10,000 or more from a customer, a Large Virtual Currency Transaction Report must be filed with FINTRAC, subject to applicable exceptions defined in FINTRAC guidance.

  1. Record Retention

Sunrise Casino retains all KYC records, transaction records, and reports filed with FINTRAC for a minimum of five years following the end of the business relationship or the date of the transaction, whichever is later. Records must be made available to FINTRAC within 30 days upon request.

Records are stored securely and access is restricted to authorized personnel with a legitimate compliance or operational need. Data handling practices comply with applicable Canadian privacy legislation.

  1. AML Compliance Program

Sunrise Casino maintains a documented AML compliance program that includes the following components:

  • Written AML and KYC policies and procedures.
  • Designation of a qualified compliance officer responsible for AML/ATF oversight.
  • Ongoing staff training and AML certification for personnel exposed to potential money laundering or terrorist financing risks.
  • Independent testing and internal audit of AML controls.
  • Ongoing customer due diligence and transaction monitoring procedures.
  • Regular risk assessments of products, customers, and delivery channels.
  1. Customer Obligations

Customers of Sunrise Casino are required to:

  • Provide accurate, complete, and current identification information upon request.
  • Cooperate with identity verification procedures at onboarding and at any subsequent point required by this policy.
  • Notify Sunrise Casino of any material change to their personal information.
  • Refrain from any activity that constitutes or facilitates money laundering or terrorist financing.

Failure to comply with identity verification requests may result in suspension or termination of the account and, where required by law, reporting to FINTRAC or other competent authorities.

  1. Policy Updates

This policy is reviewed on a regular basis and updated as required to reflect changes in applicable law, FINTRAC guidance, or internal risk assessments. The current version of this policy is available upon request. Continued use of Sunrise Casino services following any update to this policy constitutes acceptance of the revised terms.

  1. Contact

For questions relating to this policy or to submit identity verification documents, customers may contact the Sunrise Casino compliance team through the official support channels listed on the Sunrise Casino website.