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Anti-Money Laundering Policy

Anti-Money Laundering (AML) Policy – Chicken Road Game Canada

1. Overview

At Chicken Road Game, we are fully committed to upholding Canadian laws and best practices designed to prevent money laundering and terrorist financing. This AML Policy establishes the standards and controls we apply to detect, deter, and report any potentially illicit financial activity occurring on our gaming platform.

2. Regulatory Framework & Scope

2.1 Applicable Canadian Legislation

Our AML procedures are guided by the following regulatory standards:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
  • Guidelines issued by FINTRAC – Canada’s financial intelligence unit
  • Additional federal and provincial regulations relevant to AML and Counter-Terrorist Financing (CTF)

2.2 Scope of Application

This policy applies across all Chicken Road Game operations in Canada, including products, services, employees, contractors, and third-party providers. It outlines the baseline measures used to comply with legal obligations and manage risk effectively.

3. Core AML Practices

Know Your Customer (KYC)

We implement KYC checks during account creation and may request the following:

  • Government-issued photo ID
  • Proof of address
  • Evidence of source of funds (if required by risk level)

Anonymous or fraudulent registrations are strictly prohibited.

Risk-Based Approach

We assess each player’s profile based on a risk rating system. Enhanced Due Diligence (EDD) is triggered for:

  • Politically Exposed Persons (PEPs)
  • High-value or suspicious transactions
  • Players from jurisdictions flagged as high-risk

Ongoing Monitoring

All transactional activity, including deposits and withdrawals, is actively monitored. Unusual patterns or red flags are escalated for internal review and, if necessary, external reporting.

Suspicious Transaction Reporting (STR)

If there’s reasonable suspicion of money laundering or terrorist financing, a Suspicious Transaction Report is filed with FINTRAC. Players will not be notified of any reports to avoid “tipping off,” in accordance with Canadian law.

Staff Training

Employees receive regular training to identify suspicious activity and understand their AML obligations. All team members are aware of internal escalation protocols.

4. KYC & Customer Verification

4.1 Registration Requirements

Players must submit complete and accurate personal information when creating an account, including:

  • Full name
  • Date of birth
  • Residential address
  • Valid contact details

Verification documents may be requested to confirm the identity and location of the player.

4.2 Enhanced Due Diligence (EDD)

For high-risk users, we require further documentation, such as:

  • Detailed source of wealth
  • Employment verification
  • Additional ID or legal documents

EDD is applied based on transaction size, activity, jurisdiction, or individual profile.

4.3 Ongoing Reviews

Periodic reviews may be initiated based on:

  • Suspicious behavior
  • Changes to customer profile
  • Regulatory updates from FINTRAC or other authorities

5. Risk Monitoring & Red Flags

Player Risk Classification

Each user is assigned a risk rating based on:

  • Geography (country of residence)
  • Volume and type of transactions
  • In-game behavior and pattern changes

Transaction Monitoring

Thresholds are applied to deposits and withdrawals. The system flags:

  • Frequent small transactions
  • Activity structured to avoid thresholds
  • Unexpected third-party payments or large withdrawals

Such patterns are investigated by our compliance team.

6. Reporting & Recordkeeping

6.1 Internal Escalation

All employees must report suspicions directly to the AML Compliance Officer, who will assess the situation and determine next steps.

6.2 Reporting to FINTRAC

If suspicions are confirmed, the AML Officer will file an STR with FINTRAC in accordance with Canadian reporting standards.

Players will not be informed of any STR filings, in compliance with anti-tipping-off rules.

6.3 Record Retention

We securely store all AML-related documents—such as KYC files, STRs, and transaction histories—for at least five years, or longer if required by law.

7. High-Risk Categories

Politically Exposed Persons (PEPs)

Any individual identified as a PEP, or closely associated with one, undergoes EDD. Approval from senior management may be required for account maintenance or continued play.

High-Risk Jurisdictions

Transactions involving countries flagged by FATF or the Canadian government as high-risk are subject to stricter review and may be declined if adequate verification cannot be completed.

8. Compliance Oversight & Training

Staff Training

We provide ongoing AML/CTF training to all employees, ensuring they can:

  • Recognize red flags
  • Respond appropriately to suspicious activity
  • Follow internal reporting procedures

AML Compliance Officer

Our designated AML Officer is responsible for:

  • Overseeing the AML framework
  • Ensuring policy compliance across the business
  • Acting as a liaison with FINTRAC and other authorities

9. Policy Updates & Reviews

This policy is reviewed at least once annually or upon any change in applicable laws or regulations. Updates are logged, and all relevant employees are notified of the changes to ensure continuous compliance.

Chicken Road Game remains committed to the highest standards of integrity and compliance in the Canadian gaming industry. Through robust monitoring, staff education, and effective controls, we help safeguard our platform against misuse and ensure a safe, transparent gaming environment for all players.