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FINTRAC PEP and HIO Enhanced Due Diligence: Casino Obligations Under the PCMLTFR
Canadian casinos face distinct EDD obligations for foreign PEPs, domestic PEPs, and HIOs under PCMLTFR ss. 122-124. Know the triggers and approval…
AML & KYC
 1 hour ago
GLI-GSF-3: Security Controls Non-Gaming Vendors Must Satisfy to Integrate with a Gaming Enterprise
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AML · Financial Compliance

iGaming AML & Financial
Compliance

FINTRAC, FinCEN, the Bank Secrecy Act, and PCMLTFA decoded for online casino operators. Primary-source guidance on what you must report, when, and how.

2
Frameworks covered
87
Corpus documents indexed
$10K
CTR filing threshold
May 2026
Last updated
Explore FINTRAC requirements Explore FinCEN / BSA

Two frameworks

Two Frameworks. One Compliance Obligation.

Canadian and US online casino operators face overlapping but distinct AML regimes. FINTRAC governs Canadian reporting entities under the PCMLTFA. FinCEN governs US casinos under the Bank Secrecy Act and 31 CFR Part 1021. Both require written programs, designated compliance officers, and mandatory transaction reporting.

Canada: FINTRAC & PCMLTFA

Governing law: Proceeds of Crime (Money Laundering) and Terrorist Financing Act, SOR/2002-184

Financial Transactions and Reports Analysis Centre (FINTRAC)
Appoint a compliance officer Senior management level — must have direct access to board
Written compliance policies & procedures Must be approved by senior officer, kept current
Risk assessment (reviewed every 2 years) PCMLTFR s. 156(1) — two-year effectiveness review required
AML training program All staff who deal with clients or transactions
Large Cash Transaction Reports (≥$10,000 CAD) Filed within 15 days of receiving cash
Suspicious Transaction Reports (no minimum) Filed as soon as practicable — no threshold applies
Explore FINTRAC articles

United States: FinCEN & Bank Secrecy Act

Governing law: 31 CFR Part 1021 — Rules for Casinos and Card Clubs (up to date May 26, 2026)

Financial Crimes Enforcement Network (FinCEN), Dept. of Treasury
Written AML compliance program § 1021.210 — internal controls, independent testing, training, designated individual
Currency Transaction Reports (>$10,000 USD) § 1021.311 — cash in or cash out in a single gaming day
Suspicious Activity Reports (≥$5,000 USD) § 1021.320 — filed with FinCEN when casino knows, suspects, or has reason to suspect
Customer identification records § 1021.410 — additional records required by casinos and card clubs
Special information sharing (314(a) / 314(b)) § 1021.520 — mandatory 314(a) searches; voluntary 314(b) sharing
Due diligence for foreign correspondent accounts § 1021.610 — correspondent accounts for foreign financial institutions
Explore FinCEN / BSA articles

Quick reference

Key Thresholds at a Glance

Side-by-side comparison of mandatory reporting thresholds, program requirements, and compliance obligations across both frameworks.

Obligation 🇨🇦 Canada (FINTRAC) 🇺🇸 US (FinCEN)
Large Cash Threshold $10,000 CAD $10,000 USD
SAR / STR Threshold No minimum $5,000 USD
Compliance Officer Required (PCMLTFA s. 9.6) Required (§ 1021.210)
Written AML Program Required (PCMLTFR s. 156) Required (31 CFR 1021.210)
Effectiveness Review Every 2 years (mandatory) Not mandated (best practice)
Virtual Currency Covered under MSB rules Covered (FinCEN 2013 guidance)

⚠ Thresholds are per gaming day (US, as defined in § 1021.100) or per transaction (Canada). Aggregation rules apply in both jurisdictions — multiple transactions by or for the same person are combined. Not legal advice.

Browse by topic

Coverage by Topic

Each topic section below curates articles from the AML & KYC pillar. Click a chip to jump straight to that topic.

Compliance Programs 4 articles KYC & Customer ID 3 articles Transaction Reporting 4 articles Politically Exposed Persons 1 article Virtual Currency AML Coming soon Recordkeeping Coming soon

Compliance Programs

AML programs, policies, risk assessments, training, frameworks, and jurisdiction-specific obligations.

4

KYC & Customer ID

Customer identification, due diligence, source of funds, and risk rating.

3

Transaction Reporting

LCTR, STR, CTR, SAR — when and how to file with FINTRAC and FinCEN.

4

Politically Exposed Persons

PEP, HIO, enhanced due diligence, and senior political figure obligations.

1

Virtual Currency AML

Cryptocurrency and virtual currency AML obligations for casinos.

0

No articles published yet — first article on Virtual Currency AML is coming. Check back soon.

Recordkeeping

Casino records retention, identification records, and audit trail obligations.

0

No articles published yet — first article on Recordkeeping is coming. Check back soon.

Latest analysis

Latest AML & Financial Compliance Guides

AML & KYC

FINTRAC PEP and HIO Enhanced Due Diligence: Casino Obligations Under the PCMLTFR

Canadian casinos face distinct EDD obligations for foreign PEPs, domestic PEPs, and HIOs under PCMLTFR ss. 122-124. Know the triggers and approval…

16 min read Read
AML & KYC

Alberta iGaming Payment Processing Compliance: Deposits, Withdrawals, and Restricted Methods Under the AGLC SRIG

Alberta's SRIG bans cryptocurrency outright, permits credit cards, and splits AML oversight between AGLC and AiGC. Here's what payments teams must build…

14 min read Read
AML & KYC

Casino Currency Transaction Reports Under 31 CFR Part 1021: Filing Obligations, Aggregation, and the Structuring Prohibition

U.S. casinos and card clubs face strict BSA obligations under 31 CFR §§ 1021.311–315. Master the gaming day rule, cash-in/out taxonomy, ID…

16 min read Read
View all AML articles

Corpus

Primary Sources Indexed

Every article in this pillar cites the primary regulatory text directly — not summaries or secondary commentary. The sources below are fully indexed in our compliance corpus.

PCMLTFA (Canada)PCMLTFR SOR/2002-18431 CFR Part 1021 (FinCEN)18 U.S.C. § 1084 (Wire Act)UIGEA 2006FINTRAC Compliance Program GuidanceFINTRAC STR GuidanceFINTRAC LCTR GuidanceFINTRAC PEP / HIO GuidanceFINTRAC KYC GuidanceFinCEN 314(a) / 314(b)

All articles cite primary regulatory text. Updated May 2026. Not legal advice — verify obligations with qualified AML counsel before implementing a compliance program.