1. Introduction and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applicable to Century Casino & Hotel Edmonton, a property owned and operated by Century Casinos, Inc., located in Edmonton, Alberta, Canada.
Century Casino & Hotel Edmonton operates within a regulated gaming environment and is subject to applicable federal and provincial legislation governing casino operations in Canada, including obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and oversight by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This policy applies to all staff, management, and compliance personnel at the property, as well as to customers engaging in transactions at the venue.
The purpose of this policy is to establish the framework under which the property identifies, assesses, monitors, and reports activity that may constitute money laundering, terrorist financing, or related financial crime.
2. Regulatory Framework
Century Casino & Hotel Edmonton operates in accordance with:
- The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), as administered federally in Canada
- FINTRAC reporting and recordkeeping requirements applicable to casinos
- Provincial gaming regulations in Alberta, as administered by the relevant provincial gaming authority
- Group-level AML compliance standards established by Century Casinos, Inc.
Century Casinos, Inc. maintains a corporate AML program that applies across all its casino and racing entertainment center (REC) operations. AML certification is mandatory for all individuals at the property who are exposed to potential money laundering or terrorist financing risk. This requirement forms part of the wider Environmental, Social, and Governance (ESG) commitments of Century Casinos, Inc. and applies to Century Casino & Hotel Edmonton as an integrated component of the group’s operational network.
3. Customer Identification and Verification (KYC)
3.1 Identification Requirements
Century Casino & Hotel Edmonton is required to identify and verify the identity of customers in circumstances defined by applicable law and internal policy thresholds. Identification is collected and verified prior to or at the point of defined high-value transactions.
Acceptable identity documents include government-issued photo identification such as a passport, provincial driver’s licence, or equivalent document. The document must be valid, unexpired, and sufficient to confirm the customer’s full legal name, date of birth, and, where required, residential address.
3.2 Customer Due Diligence
A risk-based approach is applied to customer due diligence (CDD). The level of scrutiny applied to a customer is proportionate to the assessed risk associated with that individual’s activity, transaction volume, and profile.
Standard due diligence applies to the general customer population. Enhanced due diligence (EDD) is applied to customers identified as higher risk, including but not limited to high-volume players, politically exposed persons (PEPs), and customers whose transaction patterns are inconsistent with their stated or apparent profile.
For customers classified as high-rollers or VIP patrons, documentation confirming source of wealth and source of funds may be required to establish the legitimate origin of gambling funds prior to or during engagement.
3.3 Ongoing Monitoring
Customer accounts and transaction activity are subject to ongoing monitoring. This includes aggregation of currency transactions across gaming tables, electronic gaming machines, and the cage, as well as review of activity patterns for indicators of suspicious behaviour. Monitoring is conducted on a continuous basis and is not limited to single-session activity.
4. Recordkeeping
Century Casino & Hotel Edmonton maintains records of customer identification documents, transaction data, and due diligence findings in accordance with FINTRAC requirements and internal retention standards. Records are retained for the minimum period required by applicable law and are made available to regulatory authorities upon lawful request.
5. Transaction Reporting
Century Casino & Hotel Edmonton files the following reports with FINTRAC as required by the PCMLTFA:
- Large Cash Transaction Reports (LCTRs): filed when a customer conducts a cash transaction of CAD 10,000 or more in a single transaction or in multiple transactions totalling CAD 10,000 or more within a 24-hour period
- Suspicious Transaction Reports (STRs): filed when there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, regardless of the transaction amount
- Casino Disbursement Reports: filed for disbursements of CAD 10,000 or more made to a customer in a single transaction or in multiple transactions within a 24-hour period
Reporting obligations are not contingent on the completion of a transaction. An attempted transaction that raises suspicion is subject to the same reporting requirements as a completed one.
6. Staff Training and Certification
All personnel at Century Casino & Hotel Edmonton who are exposed to potential money laundering or terrorist financing risk are required to complete AML certification as mandated by Century Casinos, Inc. This requirement applies to roles including but not limited to cage cashiers, dealers, floor supervisors, and compliance officers.
Training covers recognition of suspicious behaviour, understanding of reporting obligations, customer identification procedures, and updates to regulatory requirements. Training is conducted on a regular basis and includes scenario-based components to support practical application.
7. Internal Controls and Independent Testing
Century Casino & Hotel Edmonton maintains written internal AML controls consistent with group standards and applicable regulatory requirements. These controls are reviewed periodically to assess their effectiveness and updated in response to regulatory changes or identified deficiencies.
The AML program at Century Casino & Hotel Edmonton is subject to independent testing and audit on a regular basis. The purpose of such testing is to evaluate whether internal controls are functioning as intended and whether staff are applying procedures correctly. Findings from independent reviews are reported to designated compliance personnel and addressed through corrective action where required.
8. Designated Compliance Responsibility
A designated individual or function is responsible for day-to-day AML compliance at Century Casino & Hotel Edmonton. This includes oversight of KYC procedures, review of suspicious activity, coordination of regulatory reporting, and liaison with FINTRAC and other relevant authorities as required.
9. Data Handling and Privacy
Personal information collected in the course of AML and KYC procedures is processed in accordance with the Privacy Policy of Century Casinos, Inc., which applies to all venues including Century Casino & Hotel Edmonton. Data collected for compliance purposes is used solely for those purposes and is not used for marketing or unrelated commercial activities. The Privacy Policy is available at www.cnty.com and governs the collection, use, retention, and disclosure of personal information across the group’s properties and digital channels.
10. Policy Updates
This policy is reviewed and updated as required to reflect changes in applicable legislation, FINTRAC guidance, provincial gaming regulations, and group-level compliance standards. Customers and staff are subject to the version of this policy in effect at the time of their interaction with Century Casino & Hotel Edmonton.