1. Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Genting Casino Wirral to all customers who hold or apply for an account. The policy is designed to meet obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, and the Licence Conditions and Codes of Practice (LCCP) issued by the UK Gambling Commission (UKGC).
Gambling is classified as a high-risk sector for money laundering and terrorist financing under UK law. Genting Casino Wirral is required to operate a risk-based framework that identifies, assesses, and mitigates those risks across all customer relationships and transactions.
This policy applies to every customer, regardless of the product accessed, the channel used, or the value of transactions undertaken.
2. Identity Verification at Account Opening
No customer may deposit funds, place a bet, or access any gambling product before identity verification is complete. Verification is carried out at the point of account creation and must be concluded before any gambling activity is permitted.
At a minimum, the following details are verified for every customer:
- Full legal name
- Date of birth
- Residential address
Customers must be aged 18 or over. Age is verified as part of the standard identity check. Where automated verification cannot confirm these details, documentary evidence will be requested before the account is activated.
2.1 Acceptable Identity Documents
Customers may be asked to provide one or more of the following:
- Government-issued photo identification: valid passport, UK driving licence, EU or EEA national identity card, or armed forces identity card
- Proof of residential address: a recent utility bill, bank statement, council tax bill, or official government correspondence dated within the last three months
- Payment method evidence: a photograph of the debit card used (with the middle digits obscured), a bank statement, or a summary screenshot from an e-wallet or payment service
Documents must be current and legible. The company reserves the right to request certified copies or additional documentation where the standard submission is insufficient for verification purposes.
3. Customer Due Diligence
3.1 Standard Due Diligence
Customer Due Diligence (CDD) is applied to all customers when a business relationship is established, when a transaction meets or exceeds the applicable threshold, when money laundering or terrorist financing is suspected, or when there is reason to doubt the accuracy of previously held information.
For casino transactions, CDD is required for any single transaction or series of linked transactions amounting to €2,000 or more, including token purchases, exchanges, and gaming machine use or winnings.
3.2 Enhanced Due Diligence
Enhanced Due Diligence (EDD) is applied where a customer presents a higher level of risk. Circumstances that may trigger EDD include, but are not limited to:
- Deposits or withdrawals at or above £1,700 (approximately €2,000) where AML or counter-terrorist financing risk indicators are present
- Unusual or inconsistent transaction patterns relative to the customer’s stated profile
- Identification of the customer as a Politically Exposed Person (PEP) or a close associate or family member of a PEP
- Concerns arising from ongoing monitoring of account activity
- Requests to return funds to a third party or to a payment method not used for the original deposit
Where EDD is triggered, documentation relating to the source of funds or source of wealth may be requested before further activity is permitted on the account.
3.3 Simplified Due Diligence
Simplified Due Diligence may be applied where a customer and the associated transaction type present a demonstrably low risk, in accordance with the risk-based approach set out in applicable regulations. This determination is made internally and is subject to ongoing review.
4. Ongoing Monitoring
Customer relationships are subject to continuous monitoring throughout their duration. This includes review of transaction patterns, account behaviour, and the continued accuracy of identity and address information held on file.
Where monitoring identifies activity inconsistent with a customer’s known profile, or where risk indicators emerge at any point, a review will be conducted. This may result in a request for updated documentation, a restriction on account activity, or escalation to the nominated AML officer.
Customers are required to notify the company promptly of any change to their personal details, including name, address, or financial circumstances, where those changes are relevant to their account.
5. Record Keeping
All records relating to customer due diligence, identity verification, transaction monitoring, and AML assessments are retained for a minimum of five years from the date the business relationship ends or the transaction is completed, whichever is later. This obligation applies regardless of whether the customer’s account remains active.
6. Suspicious Activity Reporting
Genting Casino Wirral maintains internal procedures for identifying and escalating suspicious activity. A nominated AML officer is responsible for receiving internal reports, assessing them, and determining whether a Suspicious Activity Report (SAR) must be submitted to the National Crime Agency (NCA).
All relevant staff are trained to recognise indicators of money laundering or terrorist financing and are required to report concerns through the internal escalation process. Failure to report is treated as a serious compliance matter.
The company is legally prohibited from disclosing to a customer or any third party that a SAR has been filed or that an investigation is under way. This restriction applies without exception.
7. Staff Training and Internal Governance
All employees with customer-facing or compliance responsibilities receive training on AML and KYC obligations, including how to identify suspicious behaviour, how to handle requests for documentation, and the consequences of non-compliance for both the business and the individual.
The AML officer operates at a senior level and reports to management on the effectiveness of AML controls. An independent audit process is maintained to test and review the adequacy of the measures in place. Staff in relevant roles are subject to screening prior to appointment and on an ongoing basis.
8. Customer Obligations
By opening and maintaining an account with Genting Casino Wirral, customers accept the following obligations:
- To provide accurate and complete information at the time of registration and at any point when additional verification is requested
- To supply requested documentation within the timeframe specified in any verification request
- To notify the company of material changes to personal or financial circumstances where relevant to the account
Where a customer fails to provide required documentation within a reasonable period, the company reserves the right to restrict or close the account and to withhold funds pending satisfactory completion of verification, in accordance with applicable law.
9. Regulatory Framework
This policy is maintained in accordance with the following:
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Proceeds of Crime Act 2002
- Gambling Act 2005
- UK Gambling Commission Licence Conditions and Codes of Practice (LCCP)
- UK Gambling Commission guidance for remote and non-remote casinos on preventing money laundering and terrorist financing
This policy is reviewed on a regular basis and updated as required to reflect changes in legislation, regulatory guidance, or the risk environment in which Genting Casino Wirral operates.