1. Purpose and Scope
This document sets out the anti-money laundering (AML) and know your customer (KYC) policy applied by Kelowna to all registered accounts held by players in Canada. The policy defines the procedures used to detect, prevent, and report activity associated with money laundering, terrorist financing, fraud, and related financial crime.
All account holders are subject to this policy regardless of account activity level or deposit frequency. The platform operates in accordance with obligations applicable to Canadian gaming operators, including those arising under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the reporting framework administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
2. Minimum Age Requirement
Account registration and access to any account function require the account holder to be at least 21 years of age. Age verification forms part of the standard identity verification process and is completed before deposit or withdrawal functions are activated.
3. Identity Verification (KYC)
3.1 When Verification Is Required
Identity verification is required before an account holder may access deposit or withdrawal functions. Verification may also be requested at any point during the account lifecycle if a review of account activity indicates that additional confirmation of identity is necessary.
3.2 Documents Accepted
Account holders must provide the following when requested:
- Government-issued photo identification: a valid passport, national identity card, or driver’s licence showing full legal name, date of birth, and photograph.
- Proof of address: a utility bill, bank statement, or official correspondence issued within the past three months, showing the account holder’s current residential address.
- Proof of payment method ownership: documentation confirming that the payment instrument used for deposits or withdrawals belongs to the registered account holder.
All submitted documents must be current, legible, and unaltered. The company reserves the right to request additional documentation if the initial submission does not meet verification requirements.
3.3 Enhanced Verification
Transactions at or above CAD 10,000, or a series of transactions that cumulatively reach that threshold within a defined period, are subject to enhanced verification procedures. In such cases, supplementary documentation regarding the source of funds may be requested in addition to standard identity documents.
4. Ongoing Transaction Monitoring
Ongoing monitoring of account activity is conducted to identify patterns or transactions that may indicate financial crime. Monitoring may cover, among other factors, deposit and withdrawal behavior, payment instrument consistency, account registration details, and session activity.
The following patterns are treated as indicators requiring review:
- Multiple accounts associated with the same IP address or device but registered under different identities.
- Payment instrument details that do not correspond to the name or address on the registered account.
- Significant deposits followed by withdrawal requests with minimal or no gaming activity.
- Deposits made through one type of payment instrument followed by withdrawal requests through a different instrument type.
Where a review identifies reasonable grounds to suspect money laundering or terrorist financing, a Suspicious Transaction Report is submitted to FINTRAC in accordance with applicable law.
5. Account Restrictions During Verification
While a verification request is pending, restrictions may be placed on the account. These restrictions may include suspension of withdrawal processing, limits on deposit activity, or temporary suspension of account access. Restrictions remain in place until the verification process is completed to the satisfaction of the company.
The company is not liable for delays in processing withdrawals or other account functions resulting from an account holder’s failure to provide requested documentation within a reasonable time.
6. Third-Party Payments
Deposits from payment instruments that are not registered in the account holder’s own name are not accepted. Withdrawals are processed only to payment instruments that belong to and are verified in the name of the registered account holder. Payments to or from third parties are not permitted under any circumstances.
7. Data Handling
Personal data and documentation collected during the KYC process are retained in accordance with Kelowna’s Privacy Policy and applicable Canadian data protection requirements. Records are kept for the minimum period required by law and are used solely for compliance, verification, and regulatory reporting purposes. Data is not shared with third parties except where required by law or by a competent regulatory authority.
8. Account Holder Obligations
Account holders are required to:
- Provide accurate and complete information at registration and throughout the account lifecycle.
- Submit requested verification documents promptly when asked.
- Notify the platform of any change to personal details, including name, address, or payment instrument information.
- Refrain from using the account for any purpose connected with money laundering, fraud, or other financial crime.
Failure to meet these obligations may result in account suspension, termination, or referral to the relevant authority.
9. Regulatory Framework
Kelowna’s AML and KYC procedures are aligned with the requirements of the PCMLTFA and FINTRAC guidance applicable to casino operators in Canada. Provincial regulatory requirements are observed where applicable to the jurisdiction in which the account holder is located. This policy is reviewed periodically and updated as required to reflect changes in applicable law or regulatory guidance.
10. Contact
For questions regarding identity verification or this policy, account holders should contact the Kelowna compliance team through the support channel available within the account portal.