- Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Grosvenor Casino St Giles. It defines the procedures, obligations, and controls maintained to prevent money laundering, counter terrorist financing, and ensure compliance with applicable UK legislation and regulatory requirements.
This policy applies to all customers who access services at Grosvenor Casino St Giles, regardless of the channel used. It governs the full customer lifecycle, from initial onboarding through ongoing account activity and, where applicable, account closure.
- Legal Framework
Grosvenor Casino St Giles operates in accordance with the following legislative and regulatory instruments:
- Proceeds of Crime Act 2002 (POCA)
- Terrorism Act 2000
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- UK Gambling Commission licence conditions and codes of practice
- Guidance issued by the UK Gambling Commission on anti-money laundering responsibilities for gambling businesses
The UK Gambling Commission has a statutory duty to ensure that gambling businesses maintain adequate controls to prevent their services from being used for money laundering or terrorist financing. Grosvenor Casino St Giles is subject to this duty and implements AML and KYC procedures in line with it.
- Risk-Based Approach
A risk-based approach is applied to all customer due diligence activities. The level of money laundering and terrorist financing risk presented by each customer is assessed, and proportionate controls are applied based on that assessment.
Factors considered in risk assessments include, but are not limited to:
- Customer profile, including nationality and country of residence
- Nature and volume of gambling activity
- Source of funds and source of wealth
- Whether the customer is a Politically Exposed Person (PEP) or a relative or close associate of a PEP
- Geographic risk, including whether the customer is connected to a high-risk or sanctioned jurisdiction as defined by FATF or relevant UK guidance
The gambling sector is recognised as an inherently high-risk industry for money laundering purposes, and controls are set accordingly.
- Customer Due Diligence (CDD)
4.1 Standard Due Diligence
Before accepting a customer or permitting gambling activity above applicable thresholds, Grosvenor Casino St Giles collects and verifies the following information:
- Full legal name
- Date of birth
- Residential address
- Government-issued photographic identification
Verification is conducted using reliable, independent documentary or electronic sources. Unverified customers are not permitted to undertake activity where verification is required to be completed prior to gambling.
4.2 Enhanced Due Diligence (EDD)
Enhanced due diligence is applied where a higher level of risk is identified. This includes, but is not limited to:
- Customers identified as Politically Exposed Persons or their associates
- Customers from high-risk or sanctioned jurisdictions
- Customers whose betting or gambling activity reaches or exceeds applicable thresholds, including daily totals that trigger mandatory review
- Customers whose transaction patterns or behaviour indicate unusual or unexplained activity
EDD measures may include collection of source of funds documentation, source of wealth evidence, bank statements, business ownership records, or other financial documentation. The company reserves the right to suspend or restrict account activity until EDD requirements are satisfied.
4.3 Source of Funds and Source of Wealth
For customers identified as high-value or high-risk, Grosvenor Casino St Giles requires verification of the origin of funds used for gambling and, where appropriate, the broader source of the customer’s wealth. Acceptable documentation includes payslips, tax returns, business accounts, investment records, or other verifiable financial evidence.
Failure to provide satisfactory source of funds or source of wealth documentation may result in restrictions being placed on the account, including suspension of gambling activity.
- Ongoing Monitoring
Continuous monitoring of customer accounts and transactions is carried out throughout the customer relationship. This monitoring is designed to detect activity that is inconsistent with the customer’s known profile, stated source of funds, or expected behaviour.
Indicators that may trigger a review include:
- Rapid or repeated deposits followed by immediate withdrawal with minimal gambling activity
- Transactions structured in a manner that appears designed to avoid reporting thresholds
- Significant and unexplained changes in gambling patterns
- Use of multiple payment instruments without clear justification
Where monitoring identifies activity that is unusual or cannot be explained to the satisfaction of the company, appropriate action will be taken, which may include requesting additional documentation, restricting account activity, or filing a report with the relevant authority.
- Suspicious Activity Reporting
Where Grosvenor Casino St Giles knows or suspects that a customer is engaged in money laundering or terrorist financing, there is a legal requirement to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA). This obligation applies regardless of the value of the transaction or the customer’s account status.
Employees are trained to identify and escalate internal suspicions through the designated reporting channel. Customers are not informed that a SAR has been filed or that they are under investigation, as doing so may constitute a tipping-off offence under POCA.
- Screening Procedures
All customers are screened against relevant PEP lists, sanctions lists, and adverse media sources at the point of onboarding and on an ongoing basis. Screening tools are updated regularly to reflect changes to applicable lists and designations.
Where a match is identified, the account is subject to review and, where required, enhanced due diligence or account restriction pending further assessment.
- Governance and Internal Controls
8.1 Compliance Officer and Nominated Officer
Grosvenor Casino St Giles has appointed a board-level or senior management officer responsible for compliance with AML regulations. A nominated officer has also been designated for the purpose of receiving internal disclosures and filing SARs with the NCA. The identities of these individuals are notified to the UK Gambling Commission within the timeframe required by applicable guidance.
8.2 Independent Audit
An independent audit process is maintained to assess the effectiveness of AML and KYC controls. Audit findings are reported to senior management and used to inform updates to procedures and training programmes.
8.3 Staff Screening and Training
Relevant employees are screened prior to appointment and on an ongoing basis in connection with their AML responsibilities. All staff with AML-related duties receive regular training on applicable legislation, regulatory guidance, and internal procedures. Training records are maintained and made available to the Gambling Commission upon request.
- Age Verification
KYC procedures at Grosvenor Casino St Giles include confirmation that each customer meets the minimum legal age requirement for gambling in the United Kingdom, which is 18 years. No customer is permitted to gamble prior to satisfactory age verification.
- Record Keeping
Records of all customer identification and verification documents, transaction data, and due diligence assessments are retained for a minimum period as required by applicable law and Gambling Commission guidance. Records are stored securely and made available to regulatory authorities upon lawful request.
- Policy Updates
This policy is reviewed periodically and updated to reflect changes in applicable legislation, regulatory guidance, or internal risk assessments. Customers are subject to the version of this policy in effect at the time of their interaction with Grosvenor Casino St Giles.