- Introduction
Stoney Nakoda Resort & Casino operates as a land-based casino resort located in Kananaskis, Alberta, Canada. As a casino operating within Canada, the property is subject to federal and provincial legal requirements governing anti-money laundering (AML) and know your customer (KYC) practices.
This policy describes the compliance framework applied at Stoney Nakoda Resort & Casino, the obligations placed on patrons, and the procedures followed in connection with identity verification and transaction monitoring.
The casino sector is classified as a high-risk industry for money laundering and related financial crimes under Canadian federal law. Stoney Nakoda Resort & Casino maintains internal controls, staff training programs, and procedural standards consistent with the obligations applicable to casino operators in Canada. These measures are designed to prevent the use of casino facilities for money laundering, terrorist financing, or other financial crimes.
- Legal Basis
Casino operators in Canada are required to comply with federal anti-money laundering legislation and the regulations issued under it. These obligations include maintaining a written AML compliance program, designating a compliance officer responsible for overseeing the program, conducting ongoing monitoring of patron activity, and reporting certain transactions to the relevant federal authority.
Stoney Nakoda Resort & Casino aligns its internal policies with these requirements. The AML and KYC procedures apply to all patrons engaging in gaming activities on the premises, regardless of the nature or frequency of their visits.
- Know Your Customer (KYC) Requirements
3.1 Identity Verification
Stoney Nakoda Resort & Casino requires patrons to provide valid government-issued photo identification in connection with certain transactions and activities. Identity verification is conducted when a patron engages in a transaction that meets or exceeds applicable reporting thresholds, when a patron opens a player account or credit arrangement with the property, or when casino staff identify circumstances that require verification based on risk-based assessment criteria.
Acceptable forms of identification include government-issued documents that display the patron’s full legal name, date of birth, and photograph. Examples of accepted documents include a valid passport, provincial driver’s licence, or equivalent government-issued photo identification.
3.2 Information Collected
During the identity verification process, Stoney Nakoda Resort & Casino may collect and record the following information:
- Full legal name
- Date of birth
- Residential address
- Type and number of the identification document presented
- Date of verification
This information is retained in accordance with applicable record-keeping requirements and is used solely for compliance purposes.
3.3 Source of Funds and Source of Wealth
For patrons identified as high-value or presenting elevated risk indicators, Stoney Nakoda Resort & Casino may request documentation or information relating to the source of funds used for gaming activities and, where applicable, the source of the patron’s overall wealth. This requirement applies in circumstances where the volume or nature of transactions warrants enhanced due diligence under the property’s risk-based approach.
Patrons are required to cooperate with such requests. Failure to provide satisfactory information may result in the suspension or termination of gaming access.
- Transaction Monitoring and Reporting
4.1 Monitoring Obligations
Stoney Nakoda Resort & Casino maintains procedures for monitoring patron transactions on an ongoing basis. Monitoring is applied to cash transactions, chip purchases and redemptions, and other financial activity conducted on the gaming floor. A risk-based approach is applied, with heightened monitoring for patrons or transactions that present indicators of elevated risk.
4.2 Reporting Requirements
Where a transaction meets the threshold for mandatory reporting under applicable Canadian law, Stoney Nakoda Resort & Casino is required to file a report with the relevant federal authority. This obligation applies regardless of whether the patron consents to the report being filed.
Where casino staff identify activity that is suspected to be connected to money laundering, terrorist financing, or other financial crime, a suspicious transaction report is filed in accordance with internal procedures and applicable legal requirements. The filing of such a report does not require certainty that a crime has occurred; a reasonable suspicion is sufficient to trigger the reporting obligation.
- Patron Obligations
Patrons attending Stoney Nakoda Resort & Casino are required to:
- Present valid government-issued photo identification when requested by casino staff in connection with a transaction or compliance check.
- Provide accurate and complete information when requested as part of the identity verification or due diligence process.
- Refrain from using third-party funds for gaming activities without disclosure and verification.
- Refrain from structuring transactions in a manner intended to avoid reporting thresholds or compliance procedures.
- Cooperate with any request for additional documentation or information made by casino staff in connection with AML or KYC obligations.
Non-compliance with these obligations may result in the refusal of service, removal from the gaming floor, or reporting to the relevant authorities.
- Refusal of Service
Stoney Nakoda Resort & Casino reserves the right to refuse gaming access to any patron who declines to provide required identification or documentation, whose funds appear to be connected to unlawful activity, or who engages in conduct inconsistent with the property’s compliance obligations. This right is exercised at the discretion of casino management and in accordance with applicable law.
- Staff Training and Internal Controls
Stoney Nakoda Resort & Casino maintains a program of staff training to ensure that employees responsible for gaming operations are aware of their obligations under the AML and KYC framework. Training covers the identification of suspicious activity, the procedures for escalating concerns to the designated compliance officer, and the requirements for completing and retaining records associated with reportable transactions.
Periodic internal reviews of the AML compliance program are conducted to assess the effectiveness of existing controls and to identify areas requiring adjustment.
- Data Retention
Records collected in connection with AML and KYC procedures are retained for the period required under applicable Canadian law. Retained records may include identity documents, transaction records, and reports filed with regulatory authorities.
Access to these records is restricted to authorised personnel and records are not disclosed to third parties except as required by law or by a lawful order from a competent authority.
- Minimum Age Requirement
Access to the casino area at Stoney Nakoda Resort & Casino is restricted to individuals who meet the minimum age requirement applicable under provincial gaming regulation. The minimum age for hotel check-in at the property is 18 years. Patrons who are unable to demonstrate that they meet the applicable age requirement will be refused access to gaming facilities.
- Contact and Compliance Inquiries
Patrons with questions regarding the application of AML or KYC procedures at Stoney Nakoda Resort & Casino should direct their inquiries to casino management or the designated compliance officer at the property. Requests for information about specific compliance decisions or record-keeping practices will be addressed in accordance with applicable law and the property’s internal procedures.