December 8, 2021

Guidance for Land-Based and Internet Gaming Operators

On December 31, 2021, changes to the Registrar’s Standards pertaining to the minimization of unlawful activity and money laundering will come into force.  The revisions to the Standards are driven by policy objectives that are consistent with the overall changing landscape of gaming and anti-money laundering compliance.

The Registrar is providing the following answers to common questions received since the Infobulletin announcing the upcoming changes to the Standards was published in July 2021.

6.3.1.   Maintain logs for single transactions of $3,000 or more involving the receipt of funds from, and payments to, patrons. At a minimum, the logs must include the transaction date, amount, currency and the patron’s name, account number, home address, date of birth, occupation, the date identity was ascertained, the type of ID document reviewed, ID number, issuing jurisdiction and expiry date (if applicable).

Note: Applicable to land-based gaming only.

Q. Does this Standard require tracking all patron transactions until they aggregate to a total of $3,000 or more?

A. The Standard does not require aggregation and applies to single transactions where the patron presents or receives $3,000 or more at one time.


Q. Is the patron required to present information every time a transaction of $3,000 or more is conducted?

A. Once the required information has been collected from the patron, there is no need to ask them for the same details again so long as the Operator maintains a record of the patron information that can be linked to the transaction.

6.3.2.   Implement policies, procedures and controls that specify times and situations, based on the assessment of risk, where the Operator will ascertain and reasonably corroborate a patron’s source of funds.

Q. Does this Standard allow for Operators to establish a single threshold across gaming sites?  For example, can the threshold for ascertaining source of funds just be set at $10,000 or some other specific dollar amount?

A. While this Standard does not preclude the establishment of a single threshold, the intent is for Operators to conduct a risk analysis to assist in developing appropriate situational policies, as the scope of gaming operations varies from one site to another. Should a single threshold be established, the Operator must demonstrate that a sufficient risk analysis was undertaken which led to the adoption of the threshold.  Regardless, the risk-based nature of the Standard still requires the implementation of policies to ascertain source of funds for identified high-risk situations that may not meet an established threshold.  It should further be recognized that a single threshold may create the risk of some patrons structuring transactions to avoid the threshold.  In those cases, Operators should also have policies to address this risk.


Q. Is there a difference between “source of funds” versus “source of wealth”?

A. “Source of funds” generally refers to the specific monies that are presented when a transaction is conducted, while “source of wealth” is an individual’s net worth or total assets.  For the purposes of this Standard, if a patron’s source of wealth has been ascertained and reasonably corroborated, in the absence of any suspicious indicators or information to the contrary, it can be inferred that the funds being presented are derived from that wealth.  Nonetheless, Operators should remain alert to any unusual or suspicious transactions, even in cases where source of wealth has been established.


Q.   Are Operators required to obtain proof of a patron’s “source of funds?”

A. “Reasonably corroborate” does not necessarily mean that patrons are required to provide proof of source of funds.  When ascertaining source of funds, Operators should consider the transaction in the context of the information supplied by the patron.  In some cases, the information may be corroborated through open-source searches, corporate records (if applicable) or any other publicly-available resource.  Where there are doubts about the information supplied, or in situations identified as high-risk, Operators should require additional information from the patron to assist in corroborating the source of funds and addressing the identified risk(s).

6.3.4.   Ensure that mechanisms are in place to share information, in a lawful manner, about high risks or suspicious activities with other Operators which may also be subject to similar activity.

Q. Does this Standard require a software solution or the establishment of a database?

A. A software solution or database is not required.  The intent of this Standard is to ensure communication protocols exist amongst Operators for the detection and prevention of suspected money laundering activity. Operators – including the designated reporting entities – should develop policies for information-sharing, ensuring that applicable privacy legislation and other relevant laws are taken into consideration.

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