AML / KYC Policy for Grosvenor Casino Edinburgh Maybury, United Kingdom

Description (D): AML and KYC policy for Grosvenor Casino Edinburgh Maybury, outlining identity verification, customer due diligence, ongoing monitoring, and anti-money laundering obligations under UK law.

H1: AML / KYC Policy

1. Purpose and Scope

This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied at Grosvenor Casino Edinburgh Maybury. It describes the obligations that apply to a UK-licensed gambling operator, the verification requirements placed on customers, and the procedures followed to comply with applicable law.

Operations are subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act (POCA), and the licensing conditions and codes of practice issued by the UK Gambling Commission (UKGC). These frameworks require identification of customers, assessment of financial risk, and prevention of premises and services from being used to launder money or finance terrorism.

This policy applies to all customers who access gambling at Grosvenor Casino Edinburgh Maybury, whether in person or through any account-based service operated in connection with the venue.

2. Legal Framework

The following legislation and regulatory instruments govern AML and KYC obligations relevant to Grosvenor Casino Edinburgh Maybury:

MLR 2017: designates gambling operators as obliged entities and requires risk assessments, customer due diligence, and record keeping.
Proceeds of Crime Act (POCA): core AML law that criminalises money laundering and requires reporting of suspicious activity.
UKGC Licence Conditions and Codes of Practice (LCCP): sets specific AML and KYC requirements for all UKGC-licensed operators.
UKGC AML Guidance: provides detailed operational guidance on risk-based compliance for casino and betting businesses.

3. Customer Due Diligence (CDD)

3.1 When CDD Applies

Customer Due Diligence is applied before or at the point of establishing a business relationship with a customer, and in the following circumstances:

Before allowing any gambling activity, deposit, or access to gambling products.
When a transaction or linked transactions reach or exceed the applicable threshold under MLR 2017 (referenced in UKGC guidance as approximately €2,000 or the sterling equivalent).
When there is any reason to suspect money laundering or terrorist financing.
When there are doubts about the accuracy or adequacy of previously obtained customer information.

3.2 Information Collected

As a minimum, the following information is verified for each customer:

Full legal name.
Date of birth (to confirm the customer is aged 18 or over).
Residential address.

Customers must be aged 18 or over to gamble at Grosvenor Casino Edinburgh Maybury. Age verification is completed before any gambling activity is permitted. No exceptions apply.

3.3 Documents That May Be Requested

Acceptable documents for identity and address verification include, but are not limited to:

For identity: a valid passport, national identity card, or driving licence.
For address: a recent utility bill, bank statement, or official correspondence.

Original documents or certified copies may be requested depending on the circumstances.

4. Enhanced Due Diligence (EDD)

Where a customer presents a higher level of risk, Enhanced Due Diligence is applied. EDD may be triggered by, but is not limited to, the following:

High-value deposits or gambling activity above risk thresholds set in the internal risk assessment.
Customers identified as Politically Exposed Persons (PEPs) or their close associates.
Customers with unusual or inconsistent transaction patterns.
Customers returning from a period of self-exclusion.
Any other indicator that the standard CDD process is insufficient.

Under EDD, documentation relating to source of funds and source of wealth may be requested. This may include evidence demonstrating the origin of the money used to gamble and the broader basis of the customer’s financial position. The documentation required and the method of submission are specified to the customer.

5. Ongoing Monitoring

Obligations under AML and KYC regulations continue after initial verification. Ongoing monitoring of customer activity is conducted throughout the business relationship. This includes:

Reviewing transactions for consistency with the customer’s known profile and stated circumstances.
Updating customer records when information changes or when monitoring identifies new risk indicators.
Repeating CDD or applying EDD where circumstances change or where existing information becomes insufficient.

6. Suspicious Activity Reporting

Where a transaction or activity is identified or suspected to be connected to money laundering or terrorist financing, a Suspicious Activity Report (SAR) must be submitted to the National Crime Agency (NCA). This obligation applies regardless of the amount involved.

A nominated AML officer is responsible for receiving internal disclosures from staff, assessing them, and making external reports to the NCA where required. Customers are not informed when a SAR has been or may be submitted, as doing so could constitute a tipping-off offence under POCA.

7. Record Keeping

All AML and KYC records, including copies of verification documents, transaction records, and risk assessments, are retained for a minimum of five years from the end of the business relationship or the date of the transaction, whichever is later. This requirement is set by MLR 2017 and applies without exception.

8. Staff Training

All staff at Grosvenor Casino Edinburgh Maybury who are involved in customer-facing activity or financial processing receive training on AML and KYC obligations. Training covers recognition of suspicious activity, internal reporting procedures, and the legal consequences of non-compliance. Training is reviewed and updated on a regular basis to reflect changes in regulation and UKGC guidance.

9. Business-Wide Risk Assessment

A documented business-wide risk assessment is maintained in accordance with MLR 2017. This assessment evaluates the money laundering and terrorist financing risks associated with products, customer base, geographic exposure, and delivery channels. The risk assessment is reviewed periodically and updated when material changes occur in operations or in the regulatory environment.

10. Customer Transparency

Customers are informed in advance that identity verification may be required, the circumstances in which it will be requested, and how documents should be submitted. This is consistent with UKGC expectations for transparency in the verification process.

Failure to provide required documentation when requested may result in restrictions being placed on a customer’s account or access to gambling being suspended until verification is complete.

11. Relationship to Responsible Gambling

AML and KYC controls operate alongside responsible gambling obligations. Where verification activity reveals indicators of financial vulnerability or harm, this information is taken into account in the broader customer interaction approach. KYC data may inform affordability assessments and other safeguarding measures as required by UKGC conditions.

12. Contact and Queries

Customers with questions about identity verification requirements or the status of their verification at Grosvenor Casino Edinburgh Maybury should contact the customer services team directly. Contact details are available at the venue and through official customer support channels.