1. Purpose and Scope
This document sets out the anti-money laundering (AML) and know your customer (KYC) policy applied by Peterborough to all accounts and transactions associated with Canadian users. The policy is maintained in accordance with Canada’s federal framework governing financial crime prevention, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the regulations issued under it. The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is the federal authority responsible for supervising reporting entities and receiving required disclosures.
This policy applies to all account holders, regardless of whether activity is conducted through land-based or online channels. Compliance with this policy is a condition of account access and continued use of services provided by Peterborough.
2. Legal Framework
Peterborough operates within the Canadian regulatory environment, which assigns AML and KYC obligations at both the federal and provincial levels. Federal obligations arise under the PCMLTFA and its supporting regulations. Provincial and territorial gaming authorities impose additional licensing and operational requirements that may vary by jurisdiction. Ontario’s framework, for example, involves the Alcohol and Gaming Commission of Ontario (AGCO) and iGaming Ontario. Other provinces maintain their own regulatory structures.
Where provincial requirements are more specific or more stringent than the federal baseline, Peterborough applies the higher standard.
3. AML Compliance Program
Peterborough maintains a documented AML compliance program. The core components of this program are set out below.
3.1 Compliance Officer
A designated compliance officer is responsible for overseeing the implementation and ongoing effectiveness of this policy. The compliance officer ensures that procedures remain current, that relevant staff receive appropriate training, and that required reports are submitted to FINTRAC within applicable deadlines.
3.2 Risk Assessment
Peterborough conducts and maintains a documented risk assessment covering money laundering and terrorist financing risks relevant to its operations. The assessment is reviewed periodically and updated when material changes occur in the business, the regulatory environment, or the risk landscape.
3.3 Written Policies and Procedures
Internal procedures describe how identity verification is conducted, how transactions are monitored, how suspicious activity is identified and escalated, and how required reports are prepared and submitted. These procedures are reviewed regularly for accuracy and completeness.
3.4 Employee Training
All relevant staff receive training on AML and KYC obligations, including how to identify indicators of suspicious activity and how to follow internal escalation procedures. Training is provided at onboarding and updated as required.
3.5 Effectiveness Review
The AML compliance program is subject to periodic independent review to assess whether controls are functioning as intended and whether any gaps require remediation.
4. Know Your Customer - Identity Verification
4.1 When Verification Is Required
Peterborough is required to verify the identity of account holders in connection with specified transactions and account activities. Verification obligations are triggered by, among other things, account registration, certain transaction thresholds, and risk-based assessments.
Under Canadian regulatory guidance, identity verification requirements apply in connection with casino buy-ins and disbursements reaching specified thresholds. British Columbia government material identifies a threshold of CAD 3,000 or more in buy-ins within a single day as a verification trigger. FINTRAC guidance identifies CAD 10,000 or more as a threshold for certain casino disbursement and large cash transaction reporting. International electronic funds transfers of CAD 1,000 or more may also trigger identity verification obligations in relevant circumstances. These thresholds apply to specific transaction types and do not represent a single universal rule; the applicable requirement depends on the nature of the transaction.
4.2 Information and Documents Collected
To satisfy verification requirements, Peterborough may request the following from account holders:
- Full legal name
- Date of birth
- Residential address
- Contact information
- Government-issued photo identification
- Proof of address
- Payment method documentation
- Source of funds or source of wealth information, where required by risk assessment
The specific documents requested depend on the account holder’s profile, the nature of the activity, and the applicable risk level.
4.3 Verification Methods
Identity may be verified through document review, electronic verification methods, or a combination of both, consistent with FINTRAC guidance on acceptable verification approaches. Where enhanced due diligence is required, additional steps may be taken before account access or transaction processing continues.
5. Transaction Monitoring and Reporting
5.1 Ongoing Monitoring
Peterborough monitors account activity on an ongoing basis. Monitoring covers transaction patterns, deposit and withdrawal behavior, payment method usage, and activity relative to the account holder’s established profile. Indicators that may prompt review include structuring of transactions to avoid reporting thresholds, rapid cycling of funds, third-party payment arrangements, activity inconsistent with the stated account purpose, and unusual casino-cheque activity.
5.2 Suspicious Transaction Reports
Where there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, Peterborough is required to submit a Suspicious Transaction Report (STR) to FINTRAC. This obligation applies regardless of the transaction amount.
5.3 Large Cash Transaction Reports
Cash transactions of CAD 10,000 or more received in a single transaction, or in two or more transactions totaling CAD 10,000 or more within 24 consecutive hours where Peterborough knows or suspects they are connected, are subject to Large Cash Transaction Report (LCTR) requirements.
5.4 Casino Disbursement Reports
Casino disbursements of CAD 10,000 or more are subject to reporting requirements under applicable FINTRAC guidance.
6. High-Risk Situations and Enhanced Measures
Where a customer, transaction, or relationship is assessed as presenting a higher risk of money laundering or terrorist financing, Peterborough applies enhanced due diligence measures. These may include more detailed identity verification, source-of-funds documentation, increased monitoring frequency, senior management approval for account continuation, and restrictions on account activity pending review.
High-risk indicators include, but are not limited to, politically exposed person (PEP) status, connections to high-risk jurisdictions, adverse media findings, and patterns of activity inconsistent with the account holder’s profile.
7. Consequences of Non-Compliance
Failure to provide required identity documents or information, or providing false or misleading information, may result in one or more of the following:
- Delay or suspension of account access
- Restriction or cancellation of pending transactions
- Withholding of funds pending verification
- Permanent account closure
Peterborough reserves the right to report relevant information to FINTRAC or other competent authorities as required by law, without prior notice to the account holder where disclosure would be prohibited or would compromise an investigation.
8. Data Handling
Information collected for AML and KYC purposes is used solely for compliance, fraud prevention, account security, and related legal obligations. Data is retained for the period required under applicable law and FINTRAC record-keeping requirements. Peterborough does not sell identity documentation or verification data to third parties for commercial purposes. Further details on data handling are set out in the Peterborough Privacy Policy.
9. Contact
Questions regarding this policy may be directed to the compliance team through the contact channels listed on the Peterborough website. Peterborough does not provide legal advice; account holders with questions about their own obligations under Canadian law should seek independent legal guidance.
This policy was last reviewed in 2025 and is subject to update as regulatory requirements change.