1. Overview and Legal Basis
Great Blue Heron Casino & Hotel operates as a land-based commercial casino on Scugog Island near Port Perry, Ontario, Canada. The casino is owned by the Mississaugas of Scugog Island First Nation and is managed under a service agreement involving Ontario Gaming GTA LP, which includes Great Canadian Entertainment and Brookfield Business Partners LP. The Ontario Lottery and Gaming Corporation (OLG) retains its statutory role in conducting and managing gaming activities in the province.
As a commercial casino operating in Ontario, Great Blue Heron Casino is subject to Canadian federal anti-money laundering and anti-terrorist financing legislation, specifically the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). The casino is also subject to regulatory standards set by the Alcohol and Gaming Commission of Ontario (AGCO) and to the compliance requirements embedded in its operating agreements with OLG. This policy describes how those obligations are met in practice.
All transactions, identity checks, and reporting procedures described in this document apply to in-person activity at the casino premises. Great Blue Heron Casino does not operate an online gaming platform. All gaming and financial transactions take place on-site.
2. Regulatory Framework
The casino’s anti-money laundering (AML) and know your customer (KYC) obligations arise from the following legal and regulatory sources:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), federal legislation applicable to casino businesses in Canada
- Reporting requirements to FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), Canada’s financial intelligence unit
- AGCO standards for casino operations in Ontario, including integrity, compliance, and responsible conduct requirements
- OLG contractual requirements for service providers, which incorporate AML controls and customer due diligence standards
3. Identity Verification (KYC)
3.1 General Identification Requirements
Great Blue Heron Casino requires guests to present valid government-issued photo identification in certain circumstances, including but not limited to:
- Large cash transactions
- Prize payouts
- Situations where identity verification is required under applicable law or internal risk procedures
Accepted forms of identification include:
- Government-issued driver’s licence
- Passport
- Other government-issued photo identification as determined by casino staff
Digital identification displayed on a mobile device is not accepted for verification purposes. Physical, original documents are required.
3.2 Enhanced Verification
Where a transaction or activity presents elevated risk indicators, casino staff may request additional documentation beyond standard photo identification. This may include proof of address, such as a utility bill, or other supporting documentation. The decision to apply enhanced verification is made by authorized staff in accordance with internal risk assessment procedures.
3.3 Age Verification
All guests must be at least 19 years of age to access the gaming floor. Age verification is conducted at entry and may be repeated at any point during a visit. This requirement is established under Ontario law and is enforced without exception.
4. Transaction Monitoring and Reporting
4.1 FINTRAC Reporting Thresholds
Under the PCMLTFA, Great Blue Heron Casino is required to report certain transactions to FINTRAC. Transactions involving cash or equivalent instruments at or above CAD 10,000 are subject to mandatory reporting. This applies to single transactions and may apply to multiple transactions that are determined to be related.
Guests involved in transactions at or above this threshold are required to provide valid photo identification before the transaction is completed. Refusal to provide identification results in the transaction not being processed.
4.2 Large Cash-Out Procedures
Guests requesting cash payouts above certain amounts may be subject to additional questioning and verification at the cashier cage. This is consistent with obligations to conduct customer due diligence and to assess the source and nature of funds involved in significant transactions. Staff are authorized to ask questions regarding the origin of funds and the nature of the transaction as part of this process.
4.3 Suspicious Transaction Reporting
In addition to threshold-based reporting, the casino is required to file Suspicious Transaction Reports (STRs) with FINTRAC where there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing, regardless of the amount involved. This obligation applies to all transactions and is not limited by a minimum dollar threshold.
5. Record-Keeping
Great Blue Heron Casino maintains records of identity verification, large cash transactions, and other reportable activities in accordance with the PCMLTFA and applicable AGCO standards. Records are retained on-site and are accessible only to authorized personnel. Access to these records is restricted and managed in accordance with Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) where applicable.
Retention periods for AML-related records comply with the minimum requirements established under federal law. Records may be disclosed to FINTRAC, law enforcement, or regulatory authorities as required by law.
6. Staff Responsibilities
Casino staff involved in cage operations, table game supervision, and floor management are trained to identify and respond to indicators of potential money laundering or suspicious activity. Training is conducted in accordance with the requirements of the PCMLTFA and the casino’s internal compliance program.
Staff are required to escalate concerns through designated internal channels and are not permitted to tip off a customer that a report has been or may be filed with FINTRAC or any other authority.
7. Guest Obligations
Guests at Great Blue Heron Casino are required to:
- Provide valid government-issued photo identification when requested by casino staff
- Cooperate with identity verification and transaction monitoring procedures
- Provide accurate and truthful information when asked as part of a KYC or AML procedure
- Comply with all applicable Canadian laws relating to gaming, financial transactions, and identity disclosure
Failure to comply with these requirements may result in a transaction being declined, access to the gaming floor being refused, or a report being filed with the relevant authorities.
8. Governance and Oversight
Compliance with this policy is overseen internally by designated compliance personnel and is subject to review under the casino’s operating agreements with OLG and the standards enforced by AGCO. The casino cooperates with regulatory inspections, audits, and inquiries conducted by AGCO, OLG, FINTRAC, or any other competent authority.
This policy is reviewed periodically to reflect changes in applicable legislation, regulatory guidance, or internal risk assessments. Updates to this policy take effect upon implementation and apply to all transactions and activities conducted at the casino from that date forward.
9. Contact and Compliance Inquiries
Guests with questions about identity verification procedures or transaction requirements may direct inquiries to casino staff at the cashier cage or to management on duty.
Great Blue Heron Casino is located at:
21777 Island Road, Port Perry, Ontario, Canada.