1. Introduction and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy for Genting Casino Southampton. It specifies the procedures, obligations, and controls that govern customer identification and verification, risk assessment, transaction monitoring, and the fulfilment of legal duties under UK law and UK Gambling Commission requirements.
The policy applies to all customers accessing gambling services provided by Genting Casino Southampton in both non-remote (land-based) and remote formats. All staff, compliance officers, and relevant third parties acting on behalf of Genting Casino Southampton are required to adhere to the standards set out in this document.
2. Legal Framework
Genting Casino Southampton operates under a licence issued by the UK Gambling Commission and is subject to the following legislative and regulatory frameworks:
- Proceeds of Crime Act (POCA)
- UK Money Laundering Regulations
- UK Gambling Commission AML guidance and licence conditions
- Financial Action Task Force (FATF) recommendations
- Applicable EU directives as retained or transposed into UK law
The UK Gambling Commission has a statutory duty to ensure that gambling businesses are not used for money laundering or terrorist financing. Genting Casino Southampton recognises that gambling is identified as a high-risk sector for money laundering and terrorist financing and applies controls proportionate to that level of risk.
3. Risk-Based Approach
A risk-based approach is applied to AML and KYC compliance. The extent of scrutiny applied to any customer or transaction is proportionate to the assessed risk that the customer or activity presents.
A written money laundering risk assessment is maintained, reviewed regularly, and made available for inspection by the UK Gambling Commission upon request. This assessment considers, among other matters:
- Nature and volume of transactions
- Customer profile and geographic origin
- Betting and gameplay behaviour
- Whether a customer is a Politically Exposed Person (PEP) or a close associate of a PEP
- Whether a customer is subject to sanctions or adverse media
4. Customer Identification and Verification (KYC)
4.1 Onboarding Requirements
Before a customer is permitted to gamble with Genting Casino Southampton, the customer’s identity must be identified and verified. Verification is conducted at the point of account creation or before the commencement of gambling activity, whichever occurs first.
The following information is collected and verified for all customers:
- Full legal name
- Date of birth (minimum age 18 years)
- Residential address
Verification is carried out using government-issued identity documents and, where applicable, additional data sources. Customers who cannot be verified to the required standard are not permitted to gamble.
4.2 Age Verification
The minimum age for gambling at Genting Casino Southampton is 18 years. Age verification is a mandatory component of the KYC process and is completed before any gambling activity is permitted. Customers who cannot demonstrate that they meet the minimum age requirement are not accepted.
5. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
5.1 Standard Customer Due Diligence
Ongoing customer due diligence is applied to all customers throughout their relationship with Genting Casino Southampton. CDD includes monitoring of transactions and gambling behaviour to ensure that activity is consistent with the customer’s known profile and risk classification.
5.2 Enhanced Due Diligence
Enhanced due diligence is applied to customers who present a higher level of risk. This includes, but is not limited to:
- Customers identified as Politically Exposed Persons (PEPs) or close associates of PEPs
- Customers engaging in high-value transactions or cumulative activity above defined thresholds
- Customers from jurisdictions identified by FATF as high risk
- VIP or high-roller customers
EDD measures may include:
- Source of Wealth (SOW) verification
- Source of Funds (SOF) verification
- Review of bank statements, financial records, or business ownership documentation
- Detailed background checks
Customers subject to EDD may be required to provide additional documentation before further gambling activity is permitted.
6. PEP and Sanctions Screening
Genting Casino Southampton screens customers against PEP lists, sanctions lists, and adverse media sources. Screening is conducted at onboarding and on an ongoing basis throughout the customer relationship. Where a customer is identified as a PEP or is subject to sanctions, enhanced due diligence procedures are applied without delay.
Where applicable, third parties whose payment credentials are used in connection with a customer account are also subject to screening.
7. Transaction Monitoring
Continuous monitoring of customer transactions and gambling behaviour is undertaken. Monitoring systems are designed to identify anomalies and patterns that may indicate money laundering or terrorist financing, including:
- Large or unusual deposits or withdrawals
- Structured transactions intended to avoid reporting thresholds
- Minimal gambling activity relative to deposit volumes
- Rapid or repeated cycles of deposit and withdrawal
- Sudden changes in betting patterns inconsistent with the customer’s profile
Where anomalies are identified, the relevant account may be subject to review and, where appropriate, restriction or suspension pending investigation.
8. Suspicious Activity Reporting (SARs)
Where Genting Casino Southampton knows, suspects, or has reasonable grounds to suspect that a customer is engaged in or attempting money laundering or terrorist financing, a Suspicious Activity Report (SAR) is submitted to the National Crime Agency (NCA).
Relevant employees are trained to identify and escalate suspicious activity through internal reporting channels. The nominated officer is responsible for reviewing internal reports and determining whether an external SAR to the NCA is required.
Accounts may be frozen or restricted where a SAR has been filed or where an investigation is ongoing, in accordance with legal obligations.
9. Compliance Governance
9.1 Designated Officers
Genting Casino Southampton has appointed a board-level or senior manager as the officer responsible for compliance with AML regulations. A nominated officer has also been appointed to receive and assess internal suspicion reports and to file SARs with the NCA where required.
The identities of these individuals are notified to the UK Gambling Commission within 14 days of appointment, in accordance with Commission requirements.
9.2 Independent Audit
An independent audit process is in place to assess the effectiveness of AML controls and procedures on a periodic basis. Audit findings are reviewed by senior management and are used to inform updates to this policy and associated procedures.
9.3 Staff Screening and Training
Employees in roles relevant to AML and KYC compliance are screened prior to appointment and monitored on an ongoing basis. Regular training is provided to ensure that relevant staff are aware of their obligations under this policy, current AML practices, and the requirements of the UK Gambling Commission.
10. Data Protection
Personal data collected in connection with KYC and AML procedures is processed in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR). Data is retained for the periods required by law and is not used for purposes other than those for which it was collected, except where required by law or regulatory obligation.
11. Responsible Gambling Integration
KYC and AML controls at Genting Casino Southampton are integrated with responsible gambling obligations. Age verification, identity checks, and behaviour monitoring support the enforcement of responsible gambling measures, including self-exclusion, deposit limits, playtime alerts, and referral to support services where indicators of harmful gambling behaviour are identified.
12. Policy Review
This policy is reviewed on a regular basis to ensure consistency with current UK Gambling Commission requirements, applicable legislation, and FATF guidance. Updates are implemented as required and communicated to relevant staff.