ANTI-MONEY LAUNDERING (AML) POLICY – CHICKEN ROAD GAME (CANADA)

1. Introduction

Chicken Road Game (“we,” “us,” “the Company”) is committed to complying with all applicable laws and regulations in Canada relating to the prevention of money laundering and terrorist financing. We have adopted this AML Policy to set out the procedures and controls designed to detect, prevent, and report any form of money laundering, terrorist financing, or other criminal activity that might occur through our gaming platform.

2. Legal Framework and Scope

2.1 Canadian Laws and Regulations

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
  • Related Regulations and Guidelines issued by FINTRAC (Financial Transactions and Reports Analysis Centre of Canada)
  • Any other relevant Canadian federal or provincial legislation on AML and Counter-Terrorist Financing (CTF).

2.2 Application
This AML Policy applies to all products, services, staff, and business units of Chicken Road Game in Canada. It outlines the minimum standards we observe to meet legal and regulatory AML/CTF requirements.

3. Key AML Principles

  1. Know Your Customer (KYC)

    • We conduct proper customer identification and verification to ensure no anonymous or fictitious accounts exist.
    • Depending on risk factors and regulations, we may collect additional documents (e.g., ID copies, proof of address, proof of source of funds).

  2. Risk-Based Approach

    • Clients and transactions are assessed based on potential risk factors (e.g., geographic risk, transaction volume).
    • For higher-risk players—such as Politically Exposed Persons (PEPs) or those from jurisdictions deemed high risk—enhanced due diligence (EDD) applies.

  3. Ongoing Monitoring

    • All deposits, withdrawals, and other in-game transactions are monitored for unusual or suspicious patterns.
    • If we identify something suspicious, we may suspend the account or transaction until the matter is resolved.

  4. Suspicious Transaction Reporting

    • We are obliged to file a Suspicious Transaction Report (STR) with FINTRAC in any case where there is a reasonable suspicion of money laundering or terrorist financing.
    • We do not inform the customer that a report has been or will be made (the “tipping-off” prohibition).

  5. Employee Training

    • Our staff are regularly trained on AML obligations, the recognition of suspicious transactions, and internal reporting channels.

4. Customer Identification (KYC)

4.1 Account Registration

  • All players must provide accurate personal details (full name, date of birth, address, valid email, etc.) during registration.
  • We may request additional documents (government-issued ID, proof of residency) to verify identity.

4.2 Enhanced Due Diligence (EDD)

  • For customers deemed higher risk (e.g., PEPs, large transaction volumes, unusual activity), Chicken Road Game will require further documentation regarding source of wealth or additional background checks.

4.3 Ongoing KYC Updates

  • Accounts may be re-verified periodically or upon detection of suspicious activity, changing risk profiles, or as mandated by FINTRAC and the PCMLTFA.

5. Risk-Based Monitoring

  1. Player Risk Assessment

    • Each player is assigned a risk category (e.g., standard vs. high risk). Criteria include: nationality, transaction patterns, suspicious gaming behavior, etc.

  2. Transaction Oversight

    • We set internal thresholds (daily/weekly deposit limits, unusual transaction patterns). If these thresholds are exceeded or suspicious behavior is identified, advanced checks apply.

  3. Unusual Transaction Indicators

    • Multiple small deposits in quick succession, transactions just under reporting thresholds, unexpected large withdrawals, or third-party deposits may trigger deeper investigation.

6. Reporting and Record-Keeping

6.1 Internal Reporting

  • Employees must immediately escalate any suspicions of money laundering or terrorist financing to the AML Compliance Officer, providing detailed information about the transaction or player profile in question.

6.2 External Reporting to FINTRAC

  • If the AML Compliance Officer concludes that a transaction or activity is suspicious, Chicken Road Game is required to file an STR (Suspicious Transaction Report) with FINTRAC, in line with legal deadlines and procedures.
  • Tipping-off Prohibition: We are prohibited from informing the player that such a report has been or will be submitted.

6.3 Record Retention

  • As per legal requirements, Chicken Road Game retains AML-related documents (KYC data, transaction records, STRs) for at least five years (or as mandated by law).

7. Politically Exposed Persons (PEPs) and High-Risk Jurisdictions

  • PEPs: We apply enhanced checks if a player is or is associated with a Politically Exposed Person. We verify source of funds more carefully and may seek higher-level management approval.
  • High-Risk Countries: Transactions from or to countries identified by FATF or the Canadian government as high-risk require additional due diligence or may be refused if adequate KYC cannot be performed.

8. Employee Training and AML Compliance Officer

  • Training: Our employees undergo regular AML/CTF training to identify red flags and handle suspicious transactions appropriately.
  • AML Compliance Officer: The officer oversees the implementation of this Policy, ensures internal controls align with law, and coordinates with authorities. They are the first point of contact for any AML-related inquiries or escalations.

9. Policy Review and Updates

Chicken Road Game reviews and, if necessary, revises this AML Policy at least annually or whenever there are legal/regulatory changes. All updates will be promptly documented and communicated.