1. Purpose and Legal Basis
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy that applies to Genting Casino Bolton. It describes the obligations that apply, the procedures that are followed, and the requirements placed on customers as part of the overall compliance framework.
AML and KYC obligations arise from the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) and from the Licence Conditions and Codes of Practice (LCCP) issued by the UK Gambling Commission (UKGC). As a licensed gambling operator in Great Britain, the company is required to maintain documented policies, procedures, and controls designed to detect, prevent, and report money laundering and terrorist financing.
Compliance with this policy is mandatory. Failure by a customer to meet verification requirements will result in restricted or suspended account access.
2. Scope
This policy applies to all accounts registered with Genting Casino Bolton and to any individual who deposits funds, places a bet, or requests a withdrawal. It applies from the point of account creation and continues for the duration of the customer relationship.
3. Identity Verification (KYC)
3.1 When Verification Is Required
The identity and age of every customer must be verified before the customer is permitted to gamble, deposit funds, or access any gambling product. Verification must be completed at or before account creation. No grace period applies.
3.2 Information Collected
To complete identity verification, the following information is collected from each customer:
- Full legal name
- Date of birth
- Residential address
- Contact details
3.3 Accepted Documents
Customers are required to submit valid documentation to support the information provided. Accepted documents include:
Proof of identity (one of the following):
- Valid passport
- UK driving licence (full or provisional)
- National identity card issued by a recognised authority
Proof of address (one of the following, dated within the last three months):
- Utility bill (gas, electricity, water, broadband)
- Bank or building society statement
- Council tax bill
- Mortgage statement
- Official government correspondence
Additional documentation may be requested where initial submissions are unclear, expired, or insufficient to complete verification.
3.4 Proof of Payment Method
Where indicated by internal risk assessment, evidence of the payment method used to fund an account may be requested. This may include:
- A copy of a bank card
- A screenshot of an e-wallet account
- A bank statement confirming account ownership
4. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
4.1 Standard Due Diligence
Standard Customer Due Diligence applies to all customers at the point of onboarding. This includes identity verification, age confirmation, and an initial assessment of the customer’s risk profile based on available information.
4.2 Enhanced Due Diligence
Enhanced Due Diligence is applied in the following circumstances:
- When a customer’s transactions reach or exceed the equivalent of €2,000 within a 24-hour period, including linked transactions
- When a customer is identified as a Politically Exposed Person (PEP) or a close associate of a PEP
- When transaction patterns are assessed as unusual or inconsistent with the customer’s stated profile
- When any other factor indicates elevated risk of money laundering or terrorist financing
Under EDD, documentation may be requested relating to the customer’s source of funds (SOF) and source of wealth (SOW). This may include payslips, tax returns, business accounts, or other financial records sufficient to establish the legitimate origin of funds used for gambling.
4.3 Ongoing Monitoring
Customer accounts and transaction activity are subject to ongoing monitoring throughout the customer relationship. Monitoring is designed to identify patterns or behaviours that may indicate money laundering, structuring of transactions, or other financial crime. Where changes in customer behaviour or risk profile are identified, additional verification or due diligence steps may be triggered.
5. Politically Exposed Persons (PEPs) and Sanctions Screening
All customers are screened against relevant sanctions lists and PEP databases at onboarding and on an ongoing basis. A customer identified as a PEP, or as a close family member or known associate of a PEP, is automatically subject to Enhanced Due Diligence and requires senior management approval before an account relationship is established or continued.
Screening is also carried out against adverse media sources and financial crime watchlists as part of a risk-based approach.
6. Suspicious Activity Reporting
Where there is knowledge or reasonable grounds to suspect that a customer is engaged in money laundering or terrorist financing, a Suspicious Activity Report (SAR) must be submitted to the National Crime Agency (NCA) via the SAR Online system. This obligation applies regardless of the amount involved.
It is prohibited by law to disclose to a customer that a SAR has been submitted or that an investigation is underway. This restriction is commonly referred to as the “tipping off” prohibition under the Proceeds of Crime Act 2002.
7. AML Officer and Internal Governance
Genting Casino Bolton has appointed a designated AML Officer responsible for overseeing compliance with this policy, managing internal reporting, and maintaining the relationship with regulatory authorities. The identity of the AML Officer and the nominated officer responsible for SAR submissions has been notified to the UKGC in accordance with the requirement to do so within 14 days of appointment.
Relevant staff receive training to recognise indicators of money laundering and terrorist financing, to understand their obligations under this policy, and to use internal reporting channels when suspicious activity is identified.
8. Risk Assessment
A documented business-wide risk assessment is maintained to evaluate money laundering and terrorist financing risks associated with products, customer base, delivery channels, and geographic exposure. This assessment is reviewed and updated regularly and informs the level of due diligence applied across different customer segments and transaction types.
9. Record Keeping
Records of all customer due diligence checks, identity documents, transaction histories, and risk assessments are retained for a minimum of five years following the end of the customer relationship, or longer where required by applicable law or regulatory instruction.
10. Effect on Account Access
If a customer does not provide the required documentation within the specified timeframe, or if verification cannot be completed to the satisfaction of the company, the account will be restricted or suspended. This may include preventing deposits, withdrawals, or access to gambling activity until the matter is resolved.
Withdrawal requests will not be processed where identity verification has not been completed, regardless of the account balance.
11. Regulatory Framework
This policy operates within the following legal and regulatory framework:
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Proceeds of Crime Act 2002
- UK Gambling Commission Licence Conditions and Codes of Practice (LCCP)
- UK Gambling Commission guidance on preventing money laundering and terrorist financing
- Terrorism Act 2000
This policy is reviewed periodically to reflect changes in applicable law, UKGC guidance, and the outcomes of internal risk assessments. Customers are advised to review this document regularly. Continued use of an account constitutes acceptance of the current version of this policy.