- Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applicable to Genting Casino Manchester City Centre. It describes the obligations placed on the casino as a licensed gambling operator under the regulatory framework established by the UK Gambling Commission (UKGC), and the corresponding requirements for customers who use the services of the casino.
Operations are subject to the Gambling Commission’s Licence Conditions and Codes of Practice (LCCP), the Proceeds of Crime Act (POCA), and applicable UK money laundering regulations. Compliance with these obligations is a condition of the operating licence.
This policy applies to all customers, regardless of how they access the services of Genting Casino Manchester City Centre or the nature of their activity.
- Legal Framework
Genting Casino Manchester City Centre operates under a licence issued by the UK Gambling Commission. As a licensed gambling operator, the casino is classified as an obliged entity under UK AML legislation and is legally required to implement controls designed to prevent money laundering and terrorist financing.
The principal legal instruments governing AML and KYC obligations include:
- The Proceeds of Crime Act 2002 (POCA)
- The Terrorism Act 2000
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations
- The Gambling Commission’s LCCP and associated AML guidance
Internal procedures are reviewed in line with updates issued by the Gambling Commission, including published guidance on money laundering and terrorist financing risks within the British gambling industry.
- Know Your Customer (KYC) Requirements
3.1 Identity Verification
Before a customer may gamble, deposit funds, or access certain services, identity verification is required. Verification must confirm:
- Full legal name
- Date of birth
- Residential address
Verification is carried out using reliable and independent sources. Acceptable documentation includes, but is not limited to, a valid passport, national identity card, or driving licence for identity and age confirmation, and a recent utility bill or bank statement for address confirmation.
Electronic verification methods may be used where they meet the standards required by the Gambling Commission.
3.2 Age Verification
No customer under the age of 18 may gamble or access any gambling activity, including free-to-play versions of games. Age must be verified before gambling access is granted. Where age cannot be confirmed, access is refused until satisfactory documentation is provided.
3.3 Timing of Verification
Verification requirements are applied at the point of account creation or, where applicable, before a customer is permitted to place a bet, make a deposit, or request a withdrawal. Transactions are not processed for customers whose identity has not been confirmed to the required standard.
- Customer Due Diligence (CDD)
4.1 Standard CDD
Customer Due Diligence is applied in the following circumstances:
- When establishing a new customer relationship
- When there is suspicion of money laundering or terrorist financing activity
- When there is reason to doubt the accuracy of previously obtained identification information
- When a customer conducts a transaction at or above the applicable threshold
For casino transactions, CDD is triggered for single transactions or linked transactions at or above the equivalent of €2,000. This threshold applies whether the transaction is conducted in a single operation or across a series of linked operations.
4.2 Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied where a customer presents a higher level of AML risk. Circumstances that may require EDD include:
- The customer is identified as a Politically Exposed Person (PEP) or a close associate of a PEP
- The customer’s transaction patterns are unusual or inconsistent with their stated profile
- The customer deposits or wagers amounts that are disproportionate to their known financial circumstances
- Other risk indicators identified through ongoing monitoring
EDD may involve requesting documentation relating to source of funds or source of wealth. Transactions or customer relationships do not proceed where EDD requirements cannot be satisfied.
- Risk-Based Approach
The AML risk presented by each customer is assessed individually. This assessment takes into account factors including the customer’s identity, country of residence, nature and frequency of activity, and transaction values. The level of due diligence applied is proportionate to the risk identified.
Risk assessments are reviewed on an ongoing basis and updated when new information becomes available or when a customer’s activity changes in a way that alters their risk profile.
- Ongoing Monitoring
Continuous monitoring of customer accounts and transactions is carried out to identify activity that is inconsistent with a customer’s known profile, unusual in volume or frequency, or otherwise indicative of potential money laundering or terrorist financing.
Where monitoring identifies a change in risk level, additional due diligence measures are applied as appropriate, up to and including suspension of the customer relationship pending further review.
- Suspicious Activity Reporting
Where money laundering or terrorist financing is identified or suspected, a Suspicious Activity Report (SAR) is submitted to the National Crime Agency (NCA). This obligation applies regardless of the value of the transaction involved.
Staff are required to escalate any suspicion of money laundering or terrorist financing to the designated AML officer without delay. Customers are not informed when a SAR has been filed, as doing so may constitute a criminal offence under UK law (“tipping off”).
- AML Officer
Genting Casino Manchester City Centre has appointed a designated AML officer responsible for overseeing compliance with this policy. All internal suspicion reports are directed to this officer, who determines whether a SAR should be submitted to the NCA and maintains oversight of AML controls.
- Staff Training
All relevant staff receive training in AML and KYC procedures. Training covers the identification of red flags, the correct escalation process for suspicious activity, and the legal obligations that apply to staff individually. Training is provided at induction and updated on a regular basis to reflect changes in regulation or guidance.
- Record Keeping
Records of all Customer Due Diligence, Enhanced Due Diligence, business relationships, and related documentation are retained for a minimum of five years from the end of the customer relationship or the date of the relevant transaction. Records are maintained in a form that allows retrieval and provision to the Gambling Commission or other competent authorities upon request.
- Customer Obligations
Customers are required to provide accurate and complete information when requested. Failure to provide satisfactory documentation results in refusal or suspension of access to services. Providing false or misleading information constitutes a serious breach of terms and may be reported to the relevant authorities.
The casino reserves the right to request documentation at any point during a customer relationship where risk assessment or monitoring activity indicates that further verification is required.
- Interaction with Safer Gambling Obligations
AML and KYC procedures operate alongside safer gambling obligations. Financial verification and identity checks may also inform assessment of customer vulnerability and affordability. Where a customer is subject to a self-exclusion arrangement or shows indicators of gambling-related harm, this information is taken into account as part of broader compliance monitoring.
- Policy Review
This policy is reviewed regularly to ensure consistency with current Gambling Commission guidance, UK AML legislation, and any updates to internal risk assessment. Material changes to the policy are reflected in the version published on the premises of Genting Casino Manchester City Centre and, where applicable, through customer-facing communications.