1. Overview and Regulatory Basis
Grosvenor Casino Swansea operates within the regulatory framework established by the UK Gambling Commission (UKGC). As a licensed casino operator in the United Kingdom, the casino is classified as a relevant person under the UK Money Laundering Regulations and is required to maintain formal anti-money laundering (AML) and know your customer (KYC) policies as a condition of its licence.
This policy sets out the obligations, procedures and standards that govern how customers are identified, how risk is assessed, how due diligence is conducted and how activity is monitored across casino operations. These requirements apply to all customers and are not discretionary. If verification and due diligence requirements are not satisfied, access to gambling services will be restricted.
2. Risk Assessment
The AML and KYC framework is based on a documented risk-based approach. The company identifies and assesses the risks of money laundering and terrorist financing to which its operations are exposed and adjusts policies, procedures and controls according to those risks.
The risk assessment is reviewed and updated on a regular basis and whenever material changes occur in the operating environment, the customer base or in guidance issued by the Gambling Commission. Responsibility for maintaining the risk assessment sits with senior management, with oversight at Board level. A nominated Money Laundering Reporting Officer (MLRO) holds day-to-day responsibility for AML compliance.
3. Customer Identity Verification
3.1 When Verification Is Required
Customer identity must be verified before gambling is permitted. Verification is required in the following circumstances:
- When a business relationship is established with a new customer
- When a transaction of €2,000 or more is carried out, whether in a single operation or through linked operations
- When a transfer of funds exceeding €1,000 is involved in an occasional transaction
- When there is suspicion of money laundering or terrorist financing, regardless of any threshold
- When there are doubts about the accuracy or adequacy of identification information previously obtained
- When a customer’s circumstances change in a way that is relevant to their risk profile
No customer is permitted to gamble before completion of identity verification. This requirement applies without exception.
3.2 Information and Documents Required
Standard identity verification requires the following information:
- Full legal name
- Date of birth
- Current residential address
This information is verified using reliable, independent sources. For remote customers, electronic identity verification is used where appropriate, provided it meets assurance standards required under Gambling Commission guidance. Where documents are submitted, current government-issued identification is required. Where a person acts on behalf of a customer, both the identity of that person and their authorisation to act in that capacity are verified.
4. Customer Due Diligence
4.1 Standard Customer Due Diligence (CDD)
Standard customer due diligence applies to all customers at the point of establishing a relationship and on an ongoing basis. CDD measures include:
- Identifying the customer and verifying their identity
- Identifying any beneficial owner and taking reasonable steps to verify their identity
- Assessing the purpose and intended nature of the business relationship
- Obtaining sufficient information to understand the customer’s expected activity
4.2 Simplified Due Diligence (SDD)
Where the risk assessment determines that a relationship or transaction presents a low degree of money laundering and terrorist financing risk, simplified due diligence may be applied. SDD does not remove the requirement for verification. It allows adjustment to the extent, timing or type of CDD measures to reflect the lower risk level.
SDD is discontinued immediately if:
- There is doubt about the accuracy of identification information
- The risk assessment changes and the relationship is no longer considered low risk
- There is suspicion of money laundering or terrorist financing
- Any condition requiring enhanced due diligence arises
4.3 Enhanced Due Diligence (EDD)
Enhanced due diligence is applied in higher-risk circumstances, including but not limited to:
- Customers connected to high-risk third countries
- Customers exhibiting unusual transaction patterns or high-value activity
- Situations where the source of funds or wealth is unclear or inconsistent with the customer’s known profile
EDD measures include:
- Obtaining additional information about the customer and any beneficial owner
- Establishing the source of funds and source of wealth
- Obtaining information on the reasons for specific transactions
- Seeking senior management approval before establishing or continuing the relationship
- Increasing the frequency and intensity of transaction monitoring
5. Ongoing Monitoring
Customer activity is monitored throughout the course of each relationship. Monitoring includes scrutiny of transactions to ensure consistency with the company’s knowledge of the customer, the customer’s profile and stated purpose. Where transactions are inconsistent with the expected pattern, or where new information indicates elevated risk, appropriate steps are taken. These may include requesting additional documentation, applying enhanced due diligence or restricting access pending further review.
Customer information is kept up to date. CDD measures are reapplied at appropriate intervals and whenever a change in circumstances warrants a review.
6. Suspicious Activity Reporting
Where activity is identified that gives rise to suspicion of money laundering or terrorist financing, a Suspicious Activity Report (SAR) is submitted to the National Crime Agency (NCA). Where applicable, a Defence Against Money Laundering (DAML) request may also be submitted before proceeding with a transaction.
As of July 2025, the threshold for submitting a DAML request increased from £1,000 to £3,000 in line with updated Gambling Commission guidance. Internal procedures reflect this change.
There is no minimum threshold for reporting suspicions. If money laundering or terrorist financing is suspected, a report is submitted regardless of the transaction value involved.
7. Third-Party Reliance
The company does not rely on third-party payment processors or business partners to conduct KYC checks or to establish source of funds on its behalf without further scrutiny. Grosvenor Casino Swansea remains ultimately responsible for ensuring that all customer checks are adequate and that AML obligations are met. Where third parties are engaged in any part of the compliance process, the money laundering risks of those relationships are assessed and appropriate oversight is maintained.
8. Staff Training
All relevant staff receive training on AML and KYC obligations appropriate to their role. Training covers recognition of suspicious activity, the correct application of CDD and EDD procedures, and internal reporting obligations. Training is updated in line with changes to regulatory guidance and emerging risk notices issued by the Gambling Commission.
9. Policy Updates
This policy is reviewed and updated in line with revisions to Gambling Commission guidance, changes to UK Money Laundering Regulations and any emerging risk notices published by the regulator. Customers are expected to cooperate with any updated verification or due diligence requirements. Failure to provide requested information may result in restrictions on account access or termination of the business relationship.