1. Purpose and Legal Basis
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Napoleons Casino Scunthorpe to all customers and account holders. The policy is maintained in accordance with the Gambling Act 2005, applicable UK Money Laundering Regulations, and the Licence Conditions and Codes of Practice (LCCP) issued by the Gambling Commission of Great Britain.
The Gambling Commission is the supervisory authority responsible for ensuring that casino and betting operators maintain controls to prevent money laundering and the financing of terrorism. Napoleons Casino Scunthorpe, as a licensed operator, is bound by the Commission’s AML guidance for remote and non-remote casinos, including the requirements set out in the fifth edition of “The Prevention of Money Laundering and Combating the Financing of Terrorism” guidance document.
Compliance with this policy is mandatory. Failure to satisfy identity verification or due diligence requirements may result in restrictions on account access, suspension of transactions, or closure of an account.
2. Identity Verification (KYC)
2.1 When Verification Is Required
Identity verification is applied at account opening and before a customer is permitted to deposit, access gambling services, or withdraw funds. Verification is not deferred to a later stage of the customer relationship.
In addition, verification is required in the following circumstances:
- When a single transaction or a series of linked transactions reaches or exceeds the equivalent of €2,000
- When there is any suspicion of money laundering or terrorist financing, regardless of transaction value
- When previously obtained identification documents or information are found to be inadequate or unreliable
2.2 Documents Accepted for Verification
Customers are required to provide documents sufficient to confirm identity, age, and address. Acceptable documents typically include:
- A valid passport, national identity card, or driving licence for identity and age confirmation
- A recent utility bill or bank statement as proof of residential address
All customers must be at least 18 years of age. Age verification is conducted as part of the standard KYC process and must be completed before any gambling activity is permitted.
Electronic verification tools may be used where appropriate, consistent with Gambling Commission guidance, and within a broader risk-based framework that includes manual review where necessary.
3. Customer Due Diligence
3.1 Standard Customer Due Diligence (CDD)
Standard CDD applies to all customers at the point a business relationship is established. This includes collecting and verifying identity information, understanding the nature and purpose of the customer’s intended activity, and establishing a baseline profile against which ongoing activity is monitored.
3.2 Simplified Due Diligence (SDD)
Where a customer or transaction is assessed as presenting a lower risk, simplified due diligence measures may be applied. This does not mean that verification is omitted; it means that the depth and frequency of checks may be proportionate to the assessed risk level.
3.3 Enhanced Due Diligence (EDD)
Enhanced due diligence is required in higher-risk situations. These include, but are not limited to:
- Customers identified as Politically Exposed Persons (PEPs) or their close associates
- Customers connected to high-risk third countries as designated under applicable UK regulations
- Transactions that are unusually large, complex, or inconsistent with the customer’s known profile
- Situations where the source of funds or source of wealth is unclear or requires further scrutiny
Where EDD applies, Napoleons Casino Scunthorpe may collect additional information on the customer, the nature of the business relationship, the source of funds and, where relevant, the source of wealth. Senior management approval may be required before the relationship proceeds or continues. Monitoring of the account may be conducted at an enhanced frequency.
4. Ongoing Monitoring
Ongoing monitoring of customer accounts and transactions is carried out throughout the customer relationship. Monitoring is not limited to financial thresholds. Behavioural indicators, patterns of play, deposit and withdrawal activity, and changes in customer profile are considered as part of the monitoring process.
Risk-based triggers are applied to identify activity that may be inconsistent with a customer’s known profile or that presents indicators of potential money laundering or terrorist financing. These triggers are reviewed and updated in line with current Gambling Commission guidance, including emerging risk notices issued by the Commission.
Specific risk indicators relevant to casino operations include, but are not limited to:
- Significant or repeated cash transactions
- Use of false, forged, or stolen identification documents
- Activity across multiple gambling operators, particularly across different jurisdictions
- Transaction patterns inconsistent with the customer’s stated income or financial profile
5. Source of Funds and Source of Wealth
Where a customer’s transaction activity or risk profile warrants further scrutiny, Napoleons Casino Scunthorpe may request evidence of the source of funds used for gambling and, in higher-risk cases, evidence of the source of wealth more broadly.
Customers are required to cooperate with such requests. Failure to provide satisfactory evidence within a reasonable timeframe may result in account restrictions or closure. The casino reserves the right to decline or reverse transactions pending the outcome of source of funds or source of wealth reviews.
6. Suspicious Activity Reporting
Where activity is identified that gives rise to a suspicion of money laundering or terrorist financing, a Suspicious Activity Report (SAR) will be submitted to the National Crime Agency (NCA) in accordance with UK legal obligations. This obligation applies regardless of the value of the transaction or the identity of the customer.
Customers are advised that the casino is legally prohibited from disclosing to any individual that a SAR has been filed or that an investigation is underway. This restriction, known as the tipping-off prohibition, applies under UK anti-money laundering legislation.
7. Third-Party Reliance
Napoleons Casino Scunthorpe does not delegate its AML or KYC obligations to third-party payment processors, affiliates, or other external parties. While third-party tools and electronic verification services may be used to support the verification process, the casino retains primary responsibility for all customer due diligence and source of funds assessments. Reliance on a payment processor’s own checks does not satisfy the casino’s regulatory obligations under Gambling Commission guidance.
8. Record Keeping
All records relating to customer due diligence, identity verification, transaction monitoring, and AML assessments are retained for a minimum of five years from the end of the customer relationship or the date of the relevant transaction, whichever is later. Records are maintained in a form that can be made available to the Gambling Commission or other competent authorities upon request.
9. Staff Training and Governance
Napoleons Casino Scunthorpe maintains an internal AML compliance function. A designated AML officer is responsible for receiving internal reports, overseeing compliance with this policy, and filing SARs where required. All relevant staff receive training on AML and KYC obligations appropriate to their role, and training is updated in line with regulatory developments.
10. Policy Updates
This policy is reviewed on a regular basis and updated to reflect changes in applicable legislation, Gambling Commission guidance, and identified risks. Customers are advised to review this document periodically. Continued use of the casino’s services following any update constitutes acceptance of the revised policy.