1. Purpose and Scope
This document sets out the anti-money laundering (AML) and Know Your Customer (KYC) policy applied in relation to Grosvenor Casino Southwark. It describes the legal framework in the United Kingdom, the procedures used to verify customer identity, the due diligence measures that apply, and the obligations that arise for both the casino and its customers.
This policy applies to all customers who seek to establish an account or business relationship, whether in person or through any remote channel operated by or on behalf of Grosvenor Casino Southwark. It covers identity verification, customer due diligence, enhanced due diligence, transaction monitoring, record-keeping, and the reporting of suspicious activity.
2. Legal Framework
AML and KYC obligations applicable to Grosvenor Casino Southwark derive from the following legislation and regulatory requirements in the United Kingdom:
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
- Proceeds of Crime Act 2002 (POCA)
- Gambling Commission Licence Conditions and Codes of Practice (LCCP), in particular condition 2.1.1 relating to anti-money laundering for casino businesses
- Gambling Commission guidance: “The Prevention of Money Laundering and Combating the Financing of Terrorism - Guidance for remote and non-remote casinos”
Compliance with this guidance is required as a condition of the operating licence. Failure to comply may result in regulatory action by the Gambling Commission.
3. Identity Verification (KYC)
3.1 When Verification Is Required
Customer identity is verified before any person is permitted to gamble, deposit funds, or access any gambling product. No gambling activity takes place prior to successful verification. This requirement applies without exception.
As a minimum, the following information is verified for each customer:
- Full name
- Date of birth
- Residential address
3.2 Acceptable Documents
Customers are required to provide valid documentation from the categories below, as requested.
For proof of identity, the following documents are typically acceptable:
- Valid passport
- UK driving licence (full or provisional)
- National identity card
- Armed forces identity card
For proof of address, the following documents are typically acceptable:
- Utility bill dated within the last three months
- Council tax bill
- Official government correspondence
In certain circumstances, particularly where AML checks require financial verification, additional documents may be requested. These may include bank statements, partial card images, or evidence of an e-wallet or other payment account. Customers are informed in advance of what documents are required, when they will be requested, and how they should be submitted.
3.3 Accuracy and Updates
Reasonable steps are taken to ensure that customer identity information remains accurate over time. Where there is reason to believe that information has changed or may no longer be accurate, updated documentation will be requested before continued activity is permitted.
4. Customer Due Diligence (CDD)
4.1 Standard CDD
Customer due diligence measures are applied in the following circumstances:
- When establishing a business relationship with a new customer
- When there is suspicion of money laundering or terrorist financing, regardless of any threshold
- When there are doubts about the accuracy or adequacy of previously obtained identification information
- When a customer carries out a transaction amounting to EUR 2,000 or more, whether in a single operation or in a series of linked operations
For non-remote (land-based) casino activity, identification and verification are required when a customer purchases or exchanges chips with a total value of EUR 2,000 or more within any 24-hour period.
4.2 Risk Assessment
Each customer is subject to an AML risk assessment based on factors that may include identity, country of residence, occupation, the nature of gambling activity, and transaction patterns. Customers assessed as lower risk are subject to standard CDD. Customers assessed as higher risk are subject to enhanced due diligence.
5. Enhanced Due Diligence (EDD)
Enhanced due diligence is applied to customers who present a higher risk of money laundering or terrorist financing. This includes, but is not limited to:
- Customers placing bets or making transactions totalling EUR 2,000 or more within a 24-hour period
- Customers identified as Politically Exposed Persons (PEPs) or close relatives or associates of PEPs
- Customers exhibiting unusual transaction patterns, such as structured deposits, rapid losses followed by withdrawals, or use of multiple payment methods without clear explanation
- Customers for whom the source of funds is unclear or inconsistent with known circumstances
Where EDD is triggered, additional documentation will be requested to establish the source of funds and, where appropriate, the source of wealth. Temporary account restrictions may be imposed while EDD is being completed. Withdrawals will not be processed and further deposits will not be accepted until EDD requirements are satisfied.
Holders of remote casino operating licences are required to check whether customers are PEPs or related to PEPs as part of the enhanced CDD process.
6. Ongoing Monitoring
Customer activity is monitored on a continuous basis. This includes the review of transaction volumes, bet sizes, deposit and withdrawal patterns, and other behavioural indicators that may suggest financial crime. Where monitoring identifies activity that is inconsistent with a customer’s known profile or that raises AML concerns, appropriate action will be taken. This may include requesting further information, applying additional restrictions, or filing a Suspicious Activity Report.
7. Suspicious Activity Reports (SARs)
Where activity is identified that may relate to money laundering or terrorist financing, there is a legal requirement to submit a Suspicious Activity Report to the National Crime Agency (NCA). This obligation exists regardless of the amount involved.
Tipping off is prohibited. It is not permitted to disclose to a customer that a SAR has been or may be submitted, or that an investigation is being contemplated or carried out.
8. Record-Keeping
Records of all customer due diligence, business relationships, and internal and external reports are retained for a minimum of five years from the end of the business relationship or from the date of an occasional transaction. Records are maintained securely and in a format that allows them to be retrieved promptly if required by the Gambling Commission, the NCA, or other competent authorities.
9. Governance and Responsibilities
A senior member of management is appointed as the officer responsible for regulatory compliance with AML obligations in relation to Grosvenor Casino Southwark. A nominated officer is designated to receive internal reports of suspicious activity and to determine whether a SAR should be submitted to the NCA.
All relevant staff receive regular training on money laundering risks, methods by which financial crime can occur through gambling, how to recognise red flags, and the consequences of non-compliance. Training records are maintained and reviewed periodically.
An independent audit process is in place to assess the effectiveness of AML controls. Findings from audits are reported to senior management and used to update procedures where necessary.
10. Customer Obligations
Customers are required to provide accurate and complete information when requested. Providing false, misleading, or incomplete documentation is a breach of this policy and may result in account suspension, refusal of withdrawals, and referral to relevant authorities.
Customers must notify the company promptly if any information previously provided changes, including changes to name, address, or financial circumstances.
11. Contact
Questions about this policy or about a verification request should be directed to the compliance team via the support channels listed on the official website of Grosvenor Casino Southwark.