TonyBet Casino - Player's withdrawal has been delayed and funds removed.

Dear Martin,

Thank you for your message and for taking the time to review this case.

We can confirm that the documents provided by the player during the verification process were reviewed by our relevant team. The player submitted several documents intended to demonstrate that the bank account used for the deposit was a joint account.

However, when the deposit in question was made to the player’s Tonybet account, the name reflected on the payment transaction was not the player’s name but that of another individual. As such, from our payment system’s perspective, the deposit appeared as originating from a third party.

According to our Terms and Conditions, deposits must be made only from payment methods registered solely in the player’s own name. This requirement is part of our regulatory and anti-money laundering compliance obligations.

Even in cases where a bank account may be jointly owned, it does not meet the requirement of being exclusively registered in the player’s name, as another individual retains authorised access to the same account. For this reason, the payment method could not be accepted for deposits on the player’s account.

As a result, the deposit made from the joint account was treated as a third-party payment method under our policy. Since the winnings were generated from funds deposited via this payment method, they were unfortunately removed from the player’s account in accordance with our Terms and Conditions.

We appreciate the opportunity to clarify the matter here and remain fully open to cooperating should any additional clarification be required.

Kind regards,

Tonybet Team

Hello Martin,

Thank you for continuing to review this case, and thank you to the TonyBet representative for providing further clarification.

I understand the purpose of the rule regarding payment methods being registered in the player’s name, and I appreciate that such rules are typically implemented for regulatory and anti-money-laundering compliance reasons. However, I believe the way it has been applied in this situation does not reflect the actual circumstances of the transaction.

In this case, the origin of the funds has been fully documented. The $1,000 used for the deposit came from my own primary bank account. I withdrew the funds and deposited them into a joint account that I am authorized to use. From that account, the Interac transfer was made to TonyBet. Therefore, the source of the funds is transparent and traceable, and there was no anonymous or unrelated third party involved.

During the verification process, I provided multiple forms of documentation to demonstrate this. These included a bank statement showing both account holders, documentation on bank letterhead confirming the account details, a void cheque showing the account number and my name, and additional banking screenshots. These documents were submitted specifically in response to the requests made by TonyBet support to verify the account used for the deposit.

Because of this, I believe the anti-money-laundering concern cited by TonyBet has effectively been addressed. The origin of the funds has been demonstrated, the account used is one I am authorized to access, and the transaction can be traced back to my own bank account. My intention was not to circumvent any rule, but simply to complete a deposit after reaching the daily Interac transaction limit on my primary account.

I would also respectfully note that the deposit itself was accepted by the system and gameplay was allowed to continue normally. The issue was only raised after I attempted to withdraw winnings. If the payment method had been considered invalid from the beginning, the deposit could have been declined at the time it was made.

In practice, if the gameplay had resulted in losses instead of winnings, the transaction would likely have remained accepted and the matter would have been considered closed. This is why I believe it is important that the situation be reviewed in light of the full context and documentation provided.

I appreciate the opportunity to clarify the situation further and remain fully willing to provide any additional documentation that may help resolve the matter. My hope is that the circumstances can be reviewed with consideration of the complete evidence submitted and the clear traceability of the funds.

Thank you again for your time and assistance in reviewing this case.

Dear parties,

thank you both for sharing your respective positions.

Dear casino representative,

We understand the importance of the mentioned rules, and we acknowledge that the deposit appeared in your system under another individual’s name.

And while we recognize that your terms require payment methods to be registered solely in the player’s name, we believe it should be possible to make an exception for a player, especially in case he is not acting in bad faith. We also in no way want to dismiss any verification checks, we only encourage the casino to continue with them.

For this reason, we would appreciate it if you could clarify whether there would be any possibility for the player to complete additional verification regarding the joint account and the origin of the funds, or whether the matter is considered fully closed under your internal policies regardless of any further documentation.

Dear canadianwinter18,

could you please provide us with generated statements for both the joint account and the account from which you have transferred the money? It seems I am unable to find these in the documentation provided.

Hello Martin,

Thank you for continuing to review this case and for the opportunity to provide additional documentation.

I will gladly provide the generated statements you requested. I will attach:

• A statement from my primary bank account showing the withdrawal of the funds used for the deposit.

• A statement from the joint account showing the cash deposit and the subsequent Interac transaction made to TonyBet.

These documents demonstrate the full chain of the transaction and clearly show the origin of the funds and how they moved between the accounts before the deposit was made. This should help confirm that the funds used for the deposit were my own and that the transaction can be fully traced.

For additional clarity, the sequence of events was as follows. I withdrew funds from my primary bank account and deposited them into the joint account that I am authorized to use. From that joint account, the Interac transfer of $1,000 was sent to my TonyBet account. I will provide the statements reflecting each step so the movement of funds can be verified. I've sent them to "martin.l@casino.guru" as it seems I'm unable to upload a .pdf document to this thread.

Dear canadianwinter18,

thank you for your cooperation, we will now await the response from the casino representative.

Dear Martin,

Thank you for your message and for your continued review of this case.

We fully understand your point regarding the player's explanation and the possibility of further verification. We appreciate the cooperative approach taken in this matter.

As previously mentioned, the documents submitted by the player were reviewed by our relevant team. While these documents may indicate that the account is joint, the key factor in this case remains that the payment transaction itself was received under a name different from the registered account holder.

We understand that the account may be a joint account; however, as the payment was made under a third-party name, it does not meet the requirement of being registered solely in the player’s own name and, due to regulatory requirements, must be refunded.

From a regulatory and compliance perspective, we are required to ensure that deposits are made strictly from payment methods registered in the account holder’s name and, if not, to return them to the original payment method. These rules are applied consistently to all players, and we are not able to make exceptions in individual cases.

While we acknowledge the player’s explanation regarding the origin of the funds, the fact that the payment method used does not comply with these requirements remains unchanged. For this reason, even with additional documentation, the payment method would still be considered non-compliant under our Terms and Conditions.

We appreciate your understanding and remain available should any further clarification be required.

Kind regards,

Tonybet Team

Hello Martin,

Thank you again for your continued assistance and for reviewing this case in detail.

I would like to respond to TonyBet’s latest statement and clarify several key points based on both the facts and their own Terms and Conditions.

First, I would like to emphasize that this is not a true third-party deposit scenario. The funds originated entirely from my personal bank account and were transferred by me into a joint account that I am an authorized holder of. I have already provided full documentation confirming the source of funds, the transfer trail, and my legitimate access to the account. At no point were the funds unrelated, borrowed, or controlled by an external third party. As a joint account holder, I have full legal authority to use the account and its funds, which in this case were entirely contributed by me.

TonyBet has framed this as a strict regulatory and AML issue. However, Clauses 2.22.1 and 3.1.1 clearly outline that such concerns are addressed through verification procedures, including proof of identity, payment method ownership, and source of funds. I have fully complied with all such requests, and the origin and legitimacy of the funds have been transparently verified.

Additionally, Clause 4.2 states that deposits may be refused until verification is completed. In this case, the deposit was accepted, gameplay was allowed, and no restriction was applied at the time of deposit. The issue was only raised after a withdrawal request, which suggests the deposit was not initially treated as invalid or suspicious.

Furthermore, Clause 2.13.3 specifies that winnings should be honored provided they are not reasonably suspected of being derived from fraud or illegal activity. In my case, no such suspicion has been substantiated. The funds are fully traceable and legitimate.

Given that:

• the source of funds has been fully verified,

• I am an authorized holder of the joint account used,

• there is no evidence of fraud or illicit activity,

• the deposit was accepted and gameplay permitted,

• and I have fully cooperated with all verification procedures,

the current outcome effectively penalizes a fully verified and legitimate transaction based solely on a technical naming discrepancy, rather than any actual risk or wrongdoing.

I respectfully believe that treating this as a non-compliant third-party deposit and confiscating winnings is disproportionate and not aligned with the intent of the Terms and Conditions.

I remain fully willing to provide any additional documentation if needed and would sincerely appreciate any further efforts toward a fair and reasonable resolution.

Thank you again for your time and support.

Dear parties,

thank you for sharing your respective points of view.

After reviewing the case internally, including the documentation provided by the player, we wish to confirm that as things stand, we support the player’s right to verification. We believe a verification process should be undertaken and that it is completely feasible that the funds deposited originate from the player's own account and they can be traced. The player has submitted multiple verified documents demonstrating legitimate access to the account and is willing to comply.

While we understand your internal policies regarding third-party deposits, we believe that in this instance, purely from fairness perspective, the player acted transparently and in good faith, and all AML and verification requirements can be satisfied.

I believe that even if a regulatory case of non-compliance would come up for some reason, the casino should be sufficiently covered if the verification process is diligent enough. However, in case the casino believes there are possible legal ramifications for conducting further verification processes at this point, please do let us know in detail.

Dear Martin and canadianwinter18,

Thank you for your reply and for your detailed review of this case.

We fully understand and appreciate your perspective regarding fairness and the player’s cooperation throughout the verification process. We also acknowledge that the player has provided documentation indicating access to the joint account and the origin of the funds.

However, we would like to clarify that this matter is not solely related to verification of funds or intent, but rather to strict regulatory and compliance requirements.

As previously explained, the key determining factor in this case is that the payment transaction was received under a name different from the registered account holder. Regardless of the origin of the funds or the player’s access to the account, this does not meet the requirement for deposits to be made from payment methods registered solely in the player’s own name.

From a regulatory standpoint, allowing deposits and withdrawals involving payment methods not registered in the player’s name may expose the operator to compliance risks, particularly in relation to anti-money laundering obligations and payment processing regulations. These requirements are not discretionary and must be applied consistently across all cases.

We would also like to note that this case was reviewed by the relevant regulatory authority, which supported our position and confirmed that the actions taken were in line with applicable regulatory requirements. As such, the regulator’s ruling is considered final, and unless amended or overturned by the authority, we are not in a position to further review or reconsider the resolution of this case. We must ensure that our actions remain compliant and that both our operations and our players are protected.

While we understand the argument that additional verification could demonstrate the origin of funds, such verification does not change the fundamental requirement - all transactions must be completed under the player's own name.

We appreciate your understanding and thank you for your continued cooperation.

Kind regards,

Tonybet Team

I would also like to respectfully address TonyBet’s position that this matter is strictly regulatory and not subject to discretion.

Based on my experience with other Kahnawake-licensed operators, including Yukon Gold Casino, similar situations involving joint or shared financial access have been handled differently once the source of funds and account authorization were clearly verified. This indicates that such matters are not applied in a completely uniform or automatic manner across all operators, and that risk-based assessment and discretion do exist in practice.

Additionally, TonyBet’s own Terms and Conditions suggest that these situations are not strictly binary. Clauses such as 2.22.1 and 3.1.1 rely on verification procedures to assess identity, payment methods, and source of funds, while Clause 4.2 allows deposits to be restricted pending verification. This indicates that the intended approach is to evaluate and mitigate risk through verification, rather than apply automatic punitive outcomes regardless of the circumstances.

In my case, all relevant risks have been addressed. I have demonstrated the full origin of funds, my authorized access to the account, and there has been no indication of fraud, chargeback risk, or illicit activity. It is also important to note that the payment method itself was accepted by TonyBet at the time of deposit without restriction, and the same payment flow was later used to return the original deposit. This demonstrates that the payment method was not inherently invalid or blocked within their system, and that it was operationally recognized and processed.

It is also important to note that the concept of a "player’s account" is generally defined as an account in the name of the player at a financial institution. In the case of a joint account, I am a named and authorized account holder, meaning the account is, by definition, also in my name and under my legal control. This further supports that the requirement for account ownership has been substantively met, particularly given that I have already demonstrated full ownership of the funds and complete authorization over the account. As such, the situation appears to be one of interpretation rather than a clear-cut regulatory prohibition.

It is also worth noting that established regulatory frameworks, such as those applied by the UK Gambling Commission (including Licence Conditions and Codes of Practice and requirements relating to payment method controls), as well as European regulatory approaches to remote gambling, require operators to implement risk-based anti-money laundering and verification procedures. These frameworks consistently treat discrepancies in payment method details as potential risk indicators to be assessed through due diligence, identity verification, and source of funds checks, rather than as automatic grounds for confiscation of winnings.

Importantly, these same frameworks require operators to mitigate and resolve risk through verification and monitoring, not to impose punitive outcomes once that risk has been addressed. In my case, all such checks have already been completed. My identity, access to the account, and the full origin of funds have been verified, and no indicators of fraud, money laundering, or chargeback risk remain.

As a licensed operator, TonyBet is expected to follow comparable AML and risk-based compliance principles. The existence of these regulatory frameworks demonstrates that operators are expected to assess and resolve risk, and that discretion is inherently part of that process. The position that no discretion is possible appears inconsistent with these widely accepted regulatory standards, which are designed to allow operators to evaluate individual circumstances rather than apply absolute outcomes in all cases.

Given this, it is difficult to reconcile the claim that this is a strictly non-discretionary regulatory requirement with the broader regulatory approach, as well as with TonyBet’s own reliance on verification procedures. If this were truly an absolute requirement, it would be expected to be applied uniformly across all operators and without reliance on post-transaction verification, which does not appear to reflect how such situations are handled in practice.

For these reasons, I respectfully believe this matter involves the application of internal policy and interpretation rather than an unavoidable regulatory obligation, and that a more proportionate resolution remains both possible and appropriate.

I would like to further clarify and respond to TonyBet’s position that this matter is a strict regulatory requirement with no flexibility.

Based on the Kahnawake Interactive Gaming Regulations, this position does not appear to accurately reflect how the regulatory framework is structured or applied.

Notably, the Regulations state that once a player’s identity has been verified, operators are expected to remit funds in the player’s account to the requesting player as soon as practicable (Kahnawake Interactive Gaming Regulations, 2026, Section relating to player accounts and payouts). In addition, the regulatory framework emphasizes that verified player funds should be remitted once no illicit activity is identified. In my case, my identity, access to the account, and full source of funds have all been verified, and there has been no finding of fraud, money laundering, or other illicit activity. Under these circumstances, the regulatory expectation is that funds are paid out, not confiscated.

Additionally, the Regulations clearly define specific situations where forfeiture of winnings is required, such as cases involving underage gambling. There is no equivalent provision requiring forfeiture in situations involving a verified joint account or a payment method naming discrepancy. This indicates that confiscation in cases like mine is not a mandatory regulatory outcome, but rather an interpretation applied by the operator.

Furthermore, the Regulations explicitly require that account terms must not be unfair or unreasonable to the player (Kahnawake Interactive Gaming Regulations, 2026, Section 244). Accepting a deposit, allowing gameplay, completing verification, and only then confiscating all winnings based on a technical naming discrepancy raises serious concerns regarding proportionality and fairness under this standard.

It is also important to highlight that the regulatory framework itself is built on risk-based assessment. The Regulations reference actions being taken based on assessment of circumstances, which contradicts the assertion that no flexibility exists in cases where risk has already been resolved.

In addition, TonyBet’s own Terms and Conditions reinforce that these situations are intended to be assessed through verification rather than treated as automatic violations:

Clause 3.1.1 confirms that TonyBet conducts verification procedures, including proof of identity, ownership of payment methods, and source of funds.

Clause 4.2 states that deposits may be refused or restricted until identity and/or ownership of the payment method is verified, indicating that verification is the mechanism used to resolve such concerns.

Finally, the definition of a "player’s account" within regulatory frameworks refers to an account in the name of the player at a financial institution. As a joint account holder, the account is legally in my name as well, and I have already demonstrated full ownership of the funds and authorized access to the account. This further supports that the requirement has been substantively met.

For additional context, similar regulatory frameworks (such as the UK Gambling Commission’s Licence Conditions and Codes of Practice, including requirements relating to payment methods and AML controls: https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/5-1-2-payment-methods-services) emphasize risk-based verification and due diligence, rather than automatic confiscation once funds have been verified as legitimate.

Taken together, these points demonstrate that:

the regulatory framework prioritizes verification and risk assessment,

forfeiture is only mandated in specific clearly defined cases,

and player protections require outcomes to remain fair and proportionate.

In my case, all relevant risks have been fully addressed. The source of funds has been verified, my access to the account has been proven, and no fraud, chargeback risk, or illicit activity has been identified.

For these reasons, I respectfully maintain that this outcome reflects an internal policy decision rather than a strict regulatory obligation, and that a more proportionate resolution remains both possible and appropriate.

For reference:

Kahnawake Gaming Commission – Interactive Gaming Regulations (2026):

https://gamingcommission.ca/wp-content/uploads/2026/01/Regulations-concerning-Interactive-Gaming_January-14-2026.pdf

TonyBet Terms and Conditions:

https://tonybet.com/information/terms-and-conditions

UK Gambling Commission – Payment Methods & AML Controls:

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/5-1-2-payment-methods-services

Thank you for your time and consideration.

Dear parties,

Thank you both for your detailed responses and for clarifying your respective positions.

From a fairness perspective, we continue to believe the verification procedure can be conducted. There are no obvious signs of bad faith from the player's side.

From regulatory side, to our knowledge, the case has only been reviewed by ADR, not the licensing authority itself. I believe our view may only change in case there was an explicit ruling by Kahnawake, which truly could not be overturned by the casino.

Dear canadianwinter18,

to conclude, we are leaning towards your side in this matter. I believe the best course of action would be to file a complaint to the Kahnawake authority. In the meantime, this complaint will be closed as unresolved - waiting for a regulator. After a decision is made, we will determine the next steps.

Dear casino representative,

do you agree with the proposed continuation?

We would like to ask the casino to reply to this complaint. We are extending the timer by 7 days. If the casino fails to respond in the set time frame, we will close the complaint as ‘unresolved’ which may negatively affect its rating.

Dear Martin,

Thank you for your message and for your continued review of this case.

We appreciate your detailed assessment and understand your position regarding the fairness perspective and the player’s cooperation.

With regard to the regulatory aspect, we would like to clarify that this case has been reviewed through the applicable ADR process operating within the regulatory framework. We acknowledge that this does not constitute a direct ruling from the Kahnawake Gaming Commission itself.

We respect your recommendation for the player to escalate the matter to the licensing authority and agree that, should the Kahnawake Gaming Commission issue a formal and binding decision or instruction, we will review the case accordingly and act in line with such a ruling.

At the same time, based on our current regulatory obligations and internal compliance requirements, our position regarding the use of a payment method not under the player’s name remains unchanged.

We appreciate your cooperation throughout this process and agree with the proposed continuation of awaiting a regulatory outcome.

Kind regards,

Tonybet Team

Dear Casino Representative,

Thank you for your detailed response and for your thorough involvement in the mediation process.

Dear canadianwinter18,

Unfortunately, it seems we are unable to help you further at this point, as the issue also comes down to regulatory compliance, not solely the fairness aspect of the issue. I believe the best way to proceed at this point, is to file an official complaint with Kahnawake Gaming Commission via this link.

Please let me know once you do so, and I will then be able to temporarily close the complaint accordingly.

Hello Martin,

Thank you for your continued assistance and for your careful review of this case.

I would like to confirm that I have submitted a formal complaint directly to the Kahnawake Gaming Commission requesting a full regulatory review of this matter, including both the outcome and the ADR process. At this time, I have not yet received a response.

Dear canadianwinter18,

Thank you for your cooperation throughout this case and for confirming that you have submitted the complaint to the Kahnawake Gaming Commission.

We appreciate your cooperation and patience throughout the process. At this stage, I will temporarily close the complaint while we await the regulator’s decision. Please feel free to reach out and reopen the case once the case is evaluated.

Kind regards

Martin