1. Introduction and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy of Grosvenor Casino Gloucester Road. It applies to all customer accounts, transactions, and interactions conducted through or with Grosvenor Casino Gloucester Road, whether on premises or via any remote channel.
Grosvenor Casino Gloucester Road operates under the regulatory framework established by the UK Gambling Commission and is subject to applicable UK legislation, including the Proceeds of Crime Act. The purpose of this policy is to set out the procedures and controls used to prevent money laundering, terrorist financing, and related financial crime.
This policy applies to all customers, all members of staff, and all third parties acting on behalf of Grosvenor Casino Gloucester Road. Compliance with this policy is mandatory.
2. Regulatory Framework
Grosvenor Casino Gloucester Road operates in accordance with the following regulatory and legislative requirements:
- The Proceeds of Crime Act and associated UK AML legislation
- UK Gambling Commission licence conditions and codes of practice
- Gambling Commission guidance on anti-money laundering responsibilities for gambling businesses
- Financial Action Task Force standards applicable to gambling operators
- Relevant EU AML Directives as retained or adopted in UK law
The UK Gambling Commission holds supervisory responsibility for AML compliance across the gambling sector. Grosvenor Casino Gloucester Road is required to maintain effective AML and KYC procedures as a condition of its operating licence. Failure to maintain adequate controls may result in regulatory action, including suspension or revocation of the operating licence.
3. Risk-Based Approach
Grosvenor Casino Gloucester Road applies a risk-based approach to AML and KYC compliance. The level of due diligence applied to any customer or transaction is proportionate to the assessed risk of money laundering or terrorist financing associated with that customer, product, or activity.
Risk assessments are conducted at both customer and business levels. Business-wide risk assessments are reviewed and updated on a regular basis to reflect changes in regulatory guidance, enforcement activity, and emerging risks. Customer risk profiles are assigned at onboarding and reviewed on an ongoing basis.
Factors considered in risk assessment include the customer’s identity, country of residence, source of funds, source of wealth where applicable, transaction patterns, and the nature and scale of the products used.
4. Customer Due Diligence
4.1 Standard Customer Due Diligence
Customer due diligence is conducted before a customer is permitted to engage in gambling activity. Standard CDD includes verification of the customer’s identity, age, and residential address.
Customers are required to provide valid documentation to support identity verification. Acceptable documents include government-issued photographic identification and proof of address. Documents must be current, valid, and legible.
Grosvenor Casino Gloucester Road does not permit gambling activity to commence until satisfactory identity verification has been completed.
4.2 Enhanced Due Diligence
Enhanced due diligence is applied to customers who present a higher risk profile. This includes, but is not limited to:
- Customers identified as Politically Exposed Persons (PEPs), their relatives, or close associates
- Customers whose transaction patterns or behaviour indicate elevated risk
- Customers whose total betting activity reaches or exceeds the applicable regulatory threshold within a defined period
In such cases, additional verification steps are applied before further activity is permitted.
Enhanced due diligence may include source of funds verification, source of wealth verification, and additional background checks. Customers subject to enhanced due diligence may be required to provide supporting documentation such as bank statements, payslips, tax records, or business ownership documents.
4.3 Source of Funds and Source of Wealth
Where required by the customer’s risk profile or transaction history, Grosvenor Casino Gloucester Road requests evidence of the origin of funds used for gambling and evidence of the customer’s overall financial position. Customers are required to cooperate with these requests.
Failure to provide satisfactory documentation may result in account restrictions, suspension, or closure, and may lead to the refusal of further transactions.
5. Ongoing Monitoring
Customer accounts and transactions are subject to ongoing monitoring throughout the customer relationship. Monitoring is conducted using automated systems and manual review processes. The objective of ongoing monitoring is to identify unusual or suspicious patterns of activity that may indicate money laundering, terrorist financing, or other financial crime.
Red-flag indicators that may trigger review include, but are not limited to:
- Large deposits followed by minimal gambling activity and rapid withdrawal
- Structured transactions designed to remain below reporting or monitoring thresholds
- Frequent high-value cash transactions
- Inconsistency between stated financial circumstances and observed transaction volumes
- Requests to transfer funds to third parties
Where monitoring identifies activity that raises concern, the matter is escalated to the designated compliance function for assessment and, where appropriate, further action.
6. Suspicious Activity Reporting
Grosvenor Casino Gloucester Road maintains internal procedures for the identification and reporting of suspicious activity. All relevant staff are required to report concerns to the nominated officer without delay.
Where the nominated officer determines that a Suspicious Activity Report (SAR) is required, the report is submitted to the National Crime Agency in accordance with applicable legal requirements.
Grosvenor Casino Gloucester Road does not disclose to customers that a SAR has been filed or that an investigation is underway, as such disclosure may constitute a criminal offence under UK law.
7. Politically Exposed Persons and Sanctions Screening
All customers are screened against PEP lists, sanctions lists, and adverse media sources at onboarding and on an ongoing basis. Customers identified as PEPs or as being subject to sanctions are subject to enhanced due diligence and, where applicable, restrictions or prohibitions on account activity.
Grosvenor Casino Gloucester Road does not knowingly provide services to individuals or entities subject to applicable sanctions. Where a sanctions match is identified, the account is suspended pending review and the matter is referred to the compliance function, and where appropriate to the relevant authorities.
8. Compliance Governance
Grosvenor Casino Gloucester Road has appointed a senior manager as the officer responsible for regulatory compliance and a nominated officer responsible for AML matters. The identities of these individuals are notified to the UK Gambling Commission within the timeframes required by applicable regulations.
The compliance function is responsible for:
- Maintaining and updating this policy
- Overseeing the implementation of AML and KYC procedures
- Conducting or commissioning independent audits of AML and KYC controls
- Ensuring that staff training requirements are met and kept up to date
Independent audits of AML and KYC controls are conducted on a periodic basis to assess the effectiveness of measures in place and to identify areas requiring remediation or improvement.
9. Staff Screening and Training
All relevant employees are screened prior to appointment and on an ongoing basis for AML-related risks. Staff with customer-facing, transactional, or compliance responsibilities receive regular training on:
- AML and KYC obligations
- Recognition of red-flag indicators
- Internal reporting procedures
- Applicable legal and regulatory requirements
Training records are maintained and are made available to the Gambling Commission or other competent authorities upon request.
10. Data Protection
Personal data collected for the purposes of AML and KYC compliance is processed in accordance with applicable UK data protection legislation. Personal data is retained for the period required by law and is not used for purposes other than those specified in this policy and in the applicable privacy notice.
Access to AML and KYC data is restricted to authorised personnel who require access for regulatory, legal, or operational reasons related to this policy.
11. Policy Review
This policy is reviewed at least annually and updated as required to reflect changes in legislation, Gambling Commission guidance, industry practice, and the outcomes of internal audits or enforcement developments.
The current version of this policy is available upon request.