Identity Verification Policy for Guests and Account Holders at Grey Eagle Resort & Casino

Description (D): Official identity verification policy for Grey Eagle Resort & Casino in Canada. Outlines when verification is required, which documents are accepted, and how verification data is retained and used.

H1: Identity Verification Policy

1. Purpose of This Document

This document sets out the identity verification requirements that apply to guests and account holders at Grey Eagle Resort & Casino. It explains when verification is required, which information must be provided, how verification is conducted, and how submitted documents are handled.

These requirements exist to meet obligations under Canadian anti-money laundering and counter-terrorist financing legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

Compliance with these requirements is mandatory. Failure to complete identity verification where required will result in the relevant transaction or activity being declined or suspended until verification is completed.

2. When Identity Verification Is Required

Grey Eagle Resort & Casino is required to verify the identity of any person involved in the following activities or transactions:

Cash transactions of $10,000 or more received from a single person or entity within a 24-hour period.
Large virtual currency transactions meeting the applicable FINTRAC threshold.
Casino disbursements, including winnings paid out in cash or by other means, where the amount and circumstances require verification under applicable guidance.
Extensions of credit of $3,000 or more.
Receipt of funds of $3,000 or more.
Foreign currency exchange transactions of $3,000 or more.
Any transaction or activity that gives rise to reasonable grounds to suspect money laundering, terrorist financing, or other suspicious activity, regardless of the amount involved.

Verification may also be required at account opening, during periodic account reviews, or when a material change in account activity is identified. Where verification has not been completed previously and a triggering event occurs, verification must be completed before the transaction or activity proceeds.

3. Acceptable Identity Documents

To verify identity, government-issued documentation that confirms full legal name and date of birth must be provided. Accepted documents include:

A valid Canadian passport.
A valid provincial or territorial driver’s licence.
A valid provincial or territorial identification card.
A valid Canadian Permanent Resident card.
A valid foreign passport, where applicable.

Documents must be current and unexpired at the time of submission. Photocopies, screenshots, or digitally altered images are not accepted.

Where document-based verification is supplemented by other prescribed methods under FINTRAC guidance, additional steps may be required and will be communicated at the time of verification.

4. Proof of Address

In addition to identity documentation, proof of residential address may be required in certain circumstances. Acceptable proof of address includes:

A recent utility bill.
A bank or financial institution statement.
A government-issued document that displays current residential address.

The document must be dated within the past 90 days unless otherwise specified. A post office box address is not accepted as proof of residential address.

5. Verification Methods

Grey Eagle Resort & Casino uses methods prescribed under the PCMLTFA and associated regulations to verify identity. These methods may include:

Document verification, where the information on a presented document is confirmed against the document itself and, where applicable, against a reference database or issuing authority record.
Credit file or reference database checks, where permitted under applicable regulations.
Dual-process verification, where two independent and reliable sources are used to confirm name and address.
Affiliate confirmation, where applicable in specific account or transaction contexts.

The method applied in a given situation depends on the nature of the transaction, the account type, and the information already on file. The method used and the specific requirements will be communicated to the individual concerned.

6. Obligations of the Account Holder or Guest

Guests and account holders are required to:

Provide accurate, complete, and current information when requested.
Submit documents that are genuine and unaltered.
Notify the company promptly if any information previously provided changes, including a change of legal name or residential address.
Cooperate with any follow-up requests for additional documentation or clarification.

Providing false, misleading, or fraudulent documentation is a serious matter and may result in immediate account closure, refusal of service, and referral to the relevant authorities.

7. Retention and Use of Verification Records

Records of identity verification, including copies of documents and the details of the verification method used, are retained in accordance with FINTRAC record-keeping requirements. Under current regulations, these records must be kept for a minimum of five years from the date the record was created.

Verification information is used solely for compliance, fraud prevention, and regulatory reporting purposes. It is not used for marketing and is not shared with third parties except where required by law or by a regulatory authority with jurisdiction over the operations of Grey Eagle Resort & Casino.

8. Refusal and Escalation

If identity cannot be verified using the information and documents provided, the person concerned will be informed of the reason and, where possible, advised on what additional documentation may resolve the issue. If verification cannot be completed, the relevant transaction or activity must be declined.

Where a transaction is declined on verification grounds, the matter may be raised with the compliance team for further review. Contact details are available at the property or through official guest services channels.

9. Regulatory Framework

Identity verification obligations applicable to Grey Eagle Resort & Casino are governed by the following:

Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
FINTRAC guidance: “When to verify the identity of persons and entities - Casinos.”
FINTRAC guidance: “Methods to verify the identity of persons and entities.”

Questions regarding FINTRAC guidance may be directed to FINTRAC at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

10. Updates to This Policy

This policy is reviewed periodically and updated as required to reflect changes in applicable legislation, regulatory guidance, or internal procedures. The version in effect at the time of a transaction or account activity applies.

Users are advised to review this document periodically to remain informed of any changes.