1. Purpose and Scope
1.1. This Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applies to all individuals and entities that register an account, deposit funds, place wagers, or request withdrawals through the Fresh Casino platform while located in, or resident of, Canada. The policy addresses obligations relating to identity confirmation, transaction oversight, and compliance with applicable laws intended to prevent money laundering, terrorist financing, fraud, and other financial crimes.
1.2. The AML/KYC framework is designed to align with international standards and the regulatory expectations of jurisdictions in which the platform operates or serves customers, including Canada. Fresh Casino operates under an offshore gaming license. Canadian law, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and regulations enforced by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), establishes requirements for casinos and payment intermediaries that serve Canadian customers.
1.3. This policy does not constitute legal advice and does not replace the terms and conditions governing use of Fresh Casino. Users remain responsible for understanding and complying with all laws applicable in their jurisdiction.
2. Regulatory Context in Canada
2.1. Under Canadian law, casinos that qualify as “reporting entities” must register with FINTRAC, maintain a written compliance program, appoint a compliance officer, verify customer identities, monitor transactions, keep records, and file reports on suspicious activity and large cash or virtual-currency transactions.
2.2. Reporting entities in Canada must verify identity using one of the FINTRAC-approved methods, including:
- Government-issued photo identification;
- Credit-file verification;
- Dual-process verification from two independent sources;
- Reliance on an affiliate’s verification;
- Reliance on another regulated entity’s prior verification.
2.3. Canadian AML obligations are risk-based. Firms must assess money-laundering and terrorist-financing risks associated with their customer base, products, delivery channels, and geographic exposure, and implement controls proportionate to those risks.
2.4. Fresh Casino is not directly registered as a FINTRAC reporting entity due to its offshore licensing structure. Payment processors, financial institutions, and other intermediaries that facilitate transactions between Canadian users and the platform are, however, subject to Canadian AML rules. Internal AML/KYC procedures are therefore designed to reflect the standards expected by these partners and by international practice.
3. Customer Identification and Verification (KYC)
3.1. All users must provide accurate personal information at registration, including full legal name, date of birth, residential address, email address, and phone number.
3.2. Fresh Casino reserves the right to request identity documents at any time, including but not limited to:
- At account opening or first deposit;
- Before processing any withdrawal;
- When cumulative deposits or withdrawals exceed internal thresholds;
- When transaction patterns, account activity, or other indicators suggest elevated risk;
- In response to requests from payment providers, regulators, or law-enforcement authorities.
3.3. Acceptable identity documents include:
- Government-issued photo identification (passport, national identity card, driver’s license) issued by a federal, provincial, territorial, or equivalent foreign authority, valid and current, showing full name, date of birth, photograph, and a unique identifier;
- Proof of address (utility bill, bank statement, government correspondence) issued within the past three months, showing full name and current residential address;
- Proof of payment-method ownership (screenshot or photo of card, e-wallet account, bank statement) showing the user’s name and partial account or card number.
3.4. Documents may be submitted electronically via the account dashboard or by email. Additional verification steps may be required, including live video calls, notarized copies, or certified translations, depending on risk assessment and document quality.
3.5. Accounts that do not complete identity verification within the timeframe specified in the relevant communications will be restricted. Restricted accounts may be unable to deposit, wager, or withdraw until verification is successfully completed.
4. Beneficial Ownership and Corporate Accounts
4.1. Where an account is opened by or on behalf of a corporation, partnership, trust, or other legal entity, Fresh Casino will verify the identity of the entity and identify all beneficial owners who directly or indirectly own or control 25 percent or more of the entity.
4.2. The platform may request corporate registration documents, shareholder registers, trust deeds, partnership agreements, or equivalent records, as well as identity documents for each beneficial owner and any authorized signatories.
4.3. Corporate and other entity accounts are subject to enhanced due diligence and ongoing monitoring.
5. Politically Exposed Persons (PEPs) and Sanctions Screening
5.1. Fresh Casino screens users against lists of politically exposed persons (PEPs), their relatives and close associates (RCAs), and individuals or entities subject to international sanctions.
5.2. A politically exposed person is an individual who holds or has held a prominent public function domestically or in a foreign jurisdiction, including heads of state or government, senior politicians, senior government officials, judicial or military officials, senior executives of state-owned enterprises, and important political-party officials.
5.3. Accounts identified as belonging to PEPs or RCAs, or matching sanctions lists, will be subject to enhanced due diligence, which may include source-of-funds and source-of-wealth inquiries, senior management approval, and ongoing monitoring.
5.4. Fresh Casino may decline or terminate accounts where enhanced due diligence cannot be satisfactorily completed or where the risk profile is deemed unacceptable.
6. Transaction Monitoring and Reporting
6.1. Fresh Casino monitors deposits, wagers, and withdrawals for unusual or suspicious patterns, including but not limited to:
- Transactions inconsistent with the user’s known profile or declared source of funds;
- Rapid deposits followed by immediate withdrawal requests with minimal or no wagering;
- Use of multiple payment methods or accounts within a short period;
- Structuring of transactions to avoid reporting thresholds;
- Transactions involving high-risk jurisdictions or payment channels.
6.2. Where activity is identified that may indicate money laundering, terrorist financing, fraud, or other criminal conduct, an internal investigation may be initiated and, if reasonable grounds for suspicion exist, a report may be filed with the appropriate authorities or the licensing regulator.
6.3. Users will not be notified in advance of suspicious-activity reports. Disclosure of such reports is prohibited by law in many jurisdictions and may compromise investigations.
6.4. Fresh Casino may freeze or suspend accounts, delay or refuse transactions, and request additional documentation or explanations at any time during an investigation.
7. Record Keeping
7.1. Fresh Casino retains records of customer identification, account activity, transaction history, correspondence, and compliance assessments for a minimum of five years from the date of account closure or the date of the last transaction, whichever is later.
7.2. Records are stored securely and are accessible only to authorized compliance, legal, and senior management personnel.
7.3. Records may be provided to regulators, law-enforcement agencies, payment processors, or other authorized parties where required. By using Fresh Casino services, users consent to such disclosure.
8. Source of Funds and Source of Wealth
8.1. Fresh Casino may request evidence of the source of funds used to deposit or wager, and of the source of wealth underlying those funds, particularly where:
- Cumulative deposits exceed CAD 10,000 or equivalent;
- The user is identified as a PEP or high-risk customer;
- Transaction patterns or account behavior raise questions.
8.2. Acceptable evidence includes payslips, tax returns, bank statements, sale agreements, inheritance documents, business ownership records, or other verifiable financial documentation.
8.3. Failure to provide satisfactory source-of-funds or source-of-wealth evidence within the requested timeframe may result in account restrictions, withdrawal delays, or account closure.
9. Prohibited Activities
9.1. The following activities are strictly prohibited and may result in immediate account suspension, forfeiture of funds, and reporting to authorities:
- Providing false, misleading, or fraudulent identity information or documents;
- Using another person’s identity, payment method, or account;
- Depositing funds derived from criminal activity or intended to facilitate money laundering or terrorist financing;
- Structuring transactions to evade AML controls or reporting thresholds;
- Colluding with other users to launder funds through the platform;
- Using Fresh Casino services while located in a jurisdiction where such use is prohibited.
9.2. Fresh Casino cooperates with law-enforcement and regulatory investigations. Users suspected of prohibited activities may have their accounts frozen, funds seized, and personal information disclosed to authorities without prior notice.
10. Compliance Officer and Internal Controls
10.1. Fresh Casino has appointed a designated compliance officer responsible for overseeing the implementation and effectiveness of this AML/KYC policy.
10.2. The compliance program includes risk assessments, staff training, independent audits, and regular policy reviews to maintain alignment with legal obligations and industry standards.
10.3. Employees and contractors with access to customer data or transaction information receive AML/KYC training appropriate to their role.
11. User Responsibilities
11.1. Users must:
- Provide accurate, complete, and up-to-date personal information at registration and throughout the account lifecycle;
- Respond promptly to requests for identity documents, source-of-funds evidence, or other compliance information;
- Use only payment methods registered in their own name;
- Notify Fresh Casino without undue delay of any change in personal details, including name, address, or citizenship;
- Refrain from engaging in any activity that violates this policy or applicable law.
11.2. Failure to meet these responsibilities may result in account restrictions, withdrawal delays, forfeiture of funds, or account closure.
12. Amendments and Contact
12.1. Fresh Casino may amend this AML/KYC policy at any time. Changes will be published on the website and will take effect immediately upon publication. Continued use of Fresh Casino services after publication constitutes acceptance of the revised policy.
12.2. Questions, concerns, or requests for clarification regarding this policy should be directed to the compliance team via the contact channels listed on the Fresh Casino website.
12.3. This policy is effective as of the date of publication and applies to all users in Canada.