- Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Genting Casino Fountain Park Edinburgh. It describes the procedures used to prevent money laundering and terrorist financing, verify customer identities, and meet obligations under UK law and the conditions of the licence issued by the UK Gambling Commission (UKGC).
This policy applies to all customers who hold or apply for an account, and to all transactions processed through the services of Genting Casino Fountain Park Edinburgh. It operates alongside the Responsible Gambling and Data Protection policies, which address related but distinct obligations.
- Legal Framework
The AML and KYC procedures of Genting Casino Fountain Park Edinburgh are governed by the following:
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
- UK Gambling Commission Licence Conditions and Codes of Practice (LCCP), including Condition 17.1.1
- Sector-specific AML guidance issued by the UK Gambling Commission
- Proceeds of Crime Act 2002 and Terrorism Act 2000, as applicable
The company is required to implement a risk-based approach to customer due diligence, maintain records, train staff, and report suspicious activity to the National Crime Agency (NCA) where required.
- Identity Verification at Account Opening
Genting Casino Fountain Park Edinburgh requires all customers to complete identity verification before any gambling activity, deposit, or withdrawal is permitted. This requirement applies at the point of account creation and cannot be deferred.
At a minimum, the following information is verified for every customer:
- Full legal name
- Residential address
- Date of birth
Customers must be 18 years of age or older. Access to gambling products is not permitted until age and identity have been confirmed.
Customers are informed in advance of the documents required and the method by which they should be submitted. Reasonable steps are taken to keep identity information accurate and up to date throughout the account relationship.
3.1 Accepted Identity Documents
The following documents may be requested to verify identity:
- Government-issued photo identification: valid passport, UK driving licence, EU or EEA national identity card, or armed forces identity card
- Proof of residential address: utility bill, council tax bill, or official government correspondence (for example, from HMRC or DWP), dated within three months
- Financial evidence where required: bank statement, debit card image (with sensitive digits obscured), or equivalent financial documentation
Additional documents may be requested at any stage of the account relationship if there is a reason to review or update a customer’s identity information.
- Customer Due Diligence
4.1 Standard Customer Due Diligence (CDD)
Standard customer due diligence (CDD) is applied when establishing a business relationship with a new customer, when there is suspicion of money laundering or terrorist financing, when there are doubts about the accuracy of previously collected information, and when a transaction meets or exceeds applicable thresholds.
For casino transactions, CDD is required where a single transaction or a series of linked transactions amounts to €2,000 or more. For fund transfers, the threshold is €1,000 or more.
4.2 Enhanced Due Diligence (EDD)
Enhanced due diligence (EDD) applies to customers assessed as higher risk. This includes, but is not limited to:
- Customers identified as Politically Exposed Persons (PEPs) or their relatives or close associates
- Customers displaying unusual transaction patterns or high-value activity inconsistent with their stated profile
- Customers whose source of funds cannot be adequately established through standard checks
Where EDD is triggered, additional documentation may be requested, including evidence of source of funds or source of wealth, before continued account activity is permitted.
4.3 Simplified Due Diligence (SDD)
Simplified due diligence (SDD) may apply in limited circumstances where the risk of money laundering or terrorist financing is assessed as low. The application of SDD is determined on a case-by-case basis and does not remove the obligation to monitor the customer relationship on an ongoing basis.
- Ongoing Monitoring
Customer accounts and transactions are monitored on a continuous basis. Monitoring includes review of deposit and withdrawal patterns, bet sizes, frequency of play, and any activity that appears inconsistent with a customer’s established profile or stated circumstances.
Where activity triggers a review, account access may be paused, additional information may be requested, or enhanced due diligence measures may be applied. Customers are notified where legally permissible.
Customers are also screened against financial sanctions lists and watchlists at the point of onboarding and periodically throughout the account relationship.
- Suspicious Activity Reporting
Where money laundering or terrorist financing is identified or suspected, a Suspicious Activity Report (SAR) is filed with the National Crime Agency where required by law. It is prohibited by law to disclose to a customer that a SAR has been filed or that an investigation is under way (tipping-off prohibition).
Account access may be restricted during any review or investigation without prior notice to the customer.
- Record Keeping
Records of all customer due diligence checks, identity documents, transaction data, and any reports filed are retained for a minimum of five years from the end of the business relationship or the date of the relevant transaction, whichever is later. This obligation is set out in MLR 2017 and UKGC licence conditions.
- AML Compliance Officer
Genting Casino Fountain Park Edinburgh has appointed a nominated AML officer responsible for overseeing compliance with this policy, receiving internal disclosures of suspected money laundering, and filing SARs with the NCA where required. Relevant staff receive training on AML and KYC obligations and on the consequences of non-compliance. Staff are also subject to screening prior to appointment and on an ongoing basis.
- Customer Obligations
Customers are required to provide accurate and complete information at the time of registration and when requested during the account relationship. Providing false, misleading, or incomplete information constitutes a breach of terms and may result in account suspension, closure, or referral to relevant authorities.
Customers must not use their account in a manner that facilitates money laundering, terrorist financing, or any other unlawful activity.
- Policy Updates
This policy is reviewed and updated in line with changes to applicable legislation, UKGC guidance, and internal risk assessments. The current version of this policy is made available on the website of Genting Casino Fountain Park Edinburgh. Continued use of the services following any update constitutes acceptance of the revised policy.