AML / KYC Policy

1. Purpose and Scope

This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Genting Casino Edgbaston. It describes the obligations maintained under UK law, the procedures followed when verifying customer identity, and the standards applied to monitor activity and report concerns to the relevant authorities.

Genting Casino Edgbaston operates under the regulatory oversight of the UK Gambling Commission. As a casino operator, the company is classified as a “relevant person” under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs 2017). Compliance with these Regulations, and with Gambling Commission guidance on the prevention of money laundering and the combating of terrorist financing, is a condition of the operating licence.

This policy applies to all customers who access the services of Genting Casino Edgbaston, regardless of the channel through which those services are accessed.

2. Legal Framework

AML and KYC obligations for Genting Casino Edgbaston arise from the following instruments:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, which came into force on 26 June 2017 and replaced the Money Laundering Regulations 2007.
• UK Gambling Commission licensing conditions and AML guidance for casino operators, covering both remote and non-remote operations.
• The Proceeds of Crime Act 2002 and the Terrorism Act 2000, which establish the underlying criminal offences related to money laundering and terrorist financing.

Where Gambling Commission guidance is updated, including any notices on digital identity or electronic verification, such updates are incorporated into internal procedures.

3. Customer Due Diligence (CDD)

3.1 When CDD Applies

Customer due diligence measures are applied in the following circumstances:

• When establishing a business relationship with a customer.
• When carrying out an occasional transaction at or above the applicable threshold.
• When money laundering or terrorist financing is suspected, regardless of any threshold.
• When there are doubts about the accuracy or adequacy of identification information previously obtained.

3.2 Transaction Thresholds

The MLRs 2017 specify threshold-based identification and verification requirements for casino operators. Genting Casino Edgbaston applies these as follows:

These thresholds apply whether the transaction is executed in a single operation or across several linked operations. Where transactions appear to be structured to avoid a threshold, the combined amount is treated as a single transaction for CDD purposes.

3.3 Information Collected

As part of standard CDD, the following information is collected and verified for each customer:

• Full legal name.
• Date of birth.
• Residential address.

Verification is carried out using independent and reliable sources, which may include official identity documents, electronic verification services, public records and other data sources permitted under Gambling Commission guidance.

4. Simplified and Enhanced Due Diligence

4.1 Simplified Due Diligence (SDD)

Where a customer or transaction is assessed as presenting a lower risk of money laundering or terrorist financing, simplified due diligence may be applied. SDD does not mean that no checks are carried out; it means that the extent and frequency of checks may be adjusted in proportion to the assessed risk. The basis for any SDD determination is documented.

4.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is required in higher-risk situations. EDD is applied in the following circumstances, among others:

• The customer is a Politically Exposed Person (PEP) or is a close associate or family member of a PEP.
• The customer is connected to a high-risk third country as identified by relevant UK or international guidance.
• The transaction is complex, unusually large or follows an unusual pattern with no apparent lawful purpose.
• The risk assessment identifies other indicators of elevated money laundering or terrorist financing risk.

Under EDD, additional steps are taken to establish the source of funds and, where appropriate, the source of wealth. Supporting documentation may be requested, and closer ongoing monitoring may be applied to the customer’s account and activity.

5. Ongoing Monitoring

Ongoing monitoring is carried out in respect of all customer relationships. This includes:

• Scrutiny of transactions to ensure they are consistent with knowledge of the customer, their stated source of funds and their risk profile.
• Keeping customer identification and verification information up to date.
• Identifying changes in customer behaviour or transaction patterns that may indicate money laundering, terrorist financing or financial vulnerability.

Monitoring is risk-based. Customers assessed as higher risk are subject to more frequent and more detailed review. A combination of automated systems and manual review is used to carry out this monitoring.

6. Risk Assessment

A documented money laundering and terrorist financing (ML/TF) risk assessment is maintained, covering the customer base, the products and services offered, the delivery channels used, and the jurisdictions with which customers are connected. This assessment is reviewed at least annually and whenever a material change occurs that may affect risk exposure.

The risk assessment informs the calibration of CDD procedures, the thresholds applied for enhanced scrutiny and the training provided to staff.

7. Screening

All customers are screened against relevant sanctions lists and PEP databases at onboarding and on an ongoing basis. Where a match is identified, an internal escalation procedure is followed before allowing any transaction to proceed. Services are not provided to individuals or entities subject to applicable financial sanctions.

8. Reporting Obligations

Where money laundering or terrorist financing is identified or suspected, a Suspicious Activity Report (SAR) is submitted to the National Crime Agency (NCA) via the appropriate channel, as required by law. The customer is not informed that a report has been made or is being considered, as doing so may constitute the offence of tipping off under the Proceeds of Crime Act 2002.

The nominated officer (Money Laundering Reporting Officer, MLRO) is responsible for receiving internal disclosures from staff, evaluating them and determining whether an external SAR is required.

9. Record-Keeping

Records of all customer identification and verification information, CDD and EDD documentation, transaction records and internal and external reports are retained for a minimum of five years from the end of the business relationship or the date of the transaction, as required under the MLRs 2017.

10. Staff Training

All relevant staff receive AML and counter-terrorist financing (CTF) training at induction and on an ongoing basis. Training covers recognition of suspicious activity, internal reporting procedures, legal obligations and the consequences of non-compliance. Records of training completion are maintained.

11. Governance

Responsibility for AML and KYC compliance rests with senior management. The MLRO has day-to-day responsibility for the implementation and oversight of this policy. AML controls are subject to independent review to assess their effectiveness and to identify areas for improvement.

12. Age Verification

As part of KYC obligations, the age of all customers is verified to confirm that they are 18 or over before permitting access to gambling. Age verification is carried out at the point of registration or first transaction and forms part of the standard CDD process. Gambling by persons under the age of 18 is not permitted.

13. Updates to This Policy

This policy is reviewed regularly and updated to reflect changes in applicable law, Gambling Commission guidance and the internal risk assessment. Customers are expected to cooperate with any requests for information or documentation made in connection with AML and KYC obligations. Failure to provide requested information may result in the inability to process a transaction or continue a business relationship.