- Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Cold Lake to all registered accounts. The policy is intended to prevent money laundering, terrorist financing, fraud, and other financial crime in accordance with Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
These obligations apply to every account holder, regardless of account activity level, deposit frequency, or withdrawal history. By registering an account with Cold Lake, you acknowledge and accept the procedures described in this policy.
- Minimum Age Requirement
Account registration and access to any gambling services at Cold Lake require the account holder to be at least 21 years of age. Age verification is part of the standard identity verification process and may be requested at any stage of the account lifecycle.
- Identity Verification (KYC)
3.1 When Verification Is Required
Identity verification is applied before deposit or withdrawal functions are made available to an account. Verification may also be triggered at any subsequent point, including when account information changes, when transaction patterns require review, or at regular intervals as part of ongoing monitoring.
3.2 Documents Accepted
To complete standard identity verification, the account holder must provide the following:
Government-issued photo identification
A document issued by a Canadian federal, provincial, or territorial authority that shows the holder’s full legal name, date of birth, and photograph. Acceptable documents include a passport, driver’s licence, or provincial identity card.Proof of residential address
A document issued within the past 90 days that confirms the account holder’s current residential address. Acceptable documents include a utility bill, bank statement, or official government correspondence.Payment method ownership confirmation
Where a deposit or withdrawal method is used, the platform may request documentation confirming that the account holder is the registered owner or authorised user of that payment method.
3.3 Document Standards
All submitted documents must be valid, unaltered, and legible. Expired documents are not accepted. Copies must show all four corners of the document and must not be cropped, obscured, or digitally modified. Cold Lake reserves the right to request original documents or certified copies where the quality or authenticity of a submission is in question.
- Enhanced Due Diligence
Enhanced due diligence applies in circumstances that present a higher risk of financial crime. These circumstances include, but are not limited to:
- Transactions of CAD 10,000 or more, individually or in aggregate over a defined period
- Transactions that match indicators published by FINTRAC for casino-related money laundering risk
- Account activity that is inconsistent with the account holder’s stated profile
- Requests involving third-party payment arrangements
When enhanced due diligence is triggered, additional documentation may be requested. This may include evidence of the source of funds, source of wealth, or the purpose of specific transactions. The account holder is required to respond to such requests within the timeframe specified in the notification. Failure to provide the requested information may result in account restriction or closure.
- Ongoing Monitoring
Cold Lake applies ongoing monitoring to all accounts. Monitoring covers transaction volumes, patterns, and behaviour relative to the account holder’s profile. Where activity is identified that is inconsistent with expected patterns or that matches recognised risk indicators, the account may be subject to review, temporary restriction, or escalation to the relevant authority.
FINTRAC requires that casinos report large cash transactions and suspicious transactions. Cold Lake complies with these reporting obligations. Reports submitted to FINTRAC are made in accordance with applicable law and do not require prior notification to the account holder.
- Prohibited Persons and Sanctions Screening
Cold Lake screens account holders and transactions against applicable sanctions lists and lists of prohibited persons. Accounts associated with sanctioned individuals, entities, or jurisdictions will be declined or closed. Funds held in such accounts will be handled in accordance with applicable legal requirements.
- Third-Party Transactions
Cold Lake does not permit deposits or withdrawals on behalf of a third party. All funds deposited into an account must originate from a payment method registered in the account holder’s own name. Withdrawals are processed only to a method confirmed as belonging to the account holder. Any indication of third-party funding will result in account review and may result in account suspension.
- Record Retention
Cold Lake retains identity documents, verification records, transaction records, and related correspondence for the period required under the PCMLTFA and applicable FINTRAC guidance. Records are stored securely and accessed only by authorised personnel for compliance, legal, or regulatory purposes.
- Account Restrictions and Closure
Cold Lake may restrict, suspend, or close an account where:
- The account holder fails to complete identity verification within the required timeframe
- Documents submitted are found to be invalid, expired, or inconsistent
- Transaction activity triggers an unresolved compliance review
- The account is associated with prohibited activity or a sanctioned person
- The account holder provides false or misleading information at any stage
Where an account is closed for compliance reasons, any remaining balance will be handled in accordance with applicable law and the outcome of the relevant review.
- Updates to This Policy
This policy is reviewed periodically and updated as required to reflect changes in applicable law, FINTRAC guidance, or internal compliance standards. The version published on this page is the current version. Continued use of the account following any update constitutes acceptance of the revised policy.