- Introduction and Legal Basis
Genting Casino Reading operates as a land-based casino in Reading, United Kingdom, and is subject to the regulatory framework established by the UK Gambling Commission. Under this framework, casino operators in the United Kingdom must implement Anti-Money Laundering (AML) and Know Your Customer (KYC) controls in accordance with the Gambling Act 2005, the Money Laundering Regulations, and the Licence Conditions and Codes of Practice (LCCP) issued by the Gambling Commission.
The purpose of this document is to set out the obligations, procedures, and standards applied at Genting Casino Reading in order to prevent money laundering, counter terrorist financing, and ensure that all customers meet applicable identity and eligibility requirements before accessing gambling services on the premises.
- Risk Classification and Regulatory Obligations
The UK Gambling Commission classifies casino operations as a high-risk sector for money laundering and terrorist financing. In line with this classification, Genting Casino Reading adopts a risk-based approach to AML and KYC compliance. Under this approach, the level of scrutiny applied to any individual customer or transaction is proportionate to the assessed risk associated with that customer, their activity, and the nature of the gambling services accessed.
The risk-based framework includes obligations to:
- Identify and assess the money laundering and terrorist financing risks associated with products, customers, and service delivery channels.
- Apply appropriate customer due diligence measures calibrated to the identified risk level.
- Monitor customer activity on an ongoing basis and update risk assessments as circumstances change.
- Report suspicious activity to the relevant authorities in accordance with UK law.
- Customer Due Diligence (CDD)
3.1 Standard Due Diligence
Standard customer due diligence measures apply to customers who access gambling services on the premises. Standard CDD includes the collection and verification of the following information:
- Full legal name
- Date of birth
- Residential address
Verification is conducted against reliable and independent sources. Acceptable documents for identity verification include, but are not limited to, a valid government-issued passport or a current UK photocard driving licence. Proof of address may be established through a recent utility bill, bank statement, or an equivalent official document.
3.2 Age Verification
All customers must be at least 18 years of age to access gambling services at Genting Casino Reading. Age verification is conducted at the point of entry to the premises and at gaming points where required. No individual is permitted to gamble unless age has been confirmed to the satisfaction of the company. Where age cannot be verified, access to gambling services is refused.
3.3 Enhanced Due Diligence (EDD)
Enhanced due diligence is applied to customers who present a higher level of risk. This includes, but is not limited to, customers who engage in high-value play, customers identified as VIPs or high-rollers, and customers whose activity or profile presents indicators of elevated risk.
Enhanced due diligence measures may include:
- Source of funds (SOF) checks to confirm that the funds used for gambling are derived from legitimate sources. Acceptable evidence includes bank statements, payslips, or documentation confirming business income.
- Source of wealth (SOW) checks where the broader financial background of a customer requires assessment.
- Additional identity documentation or verification steps beyond those required under standard CDD.
Customers subject to enhanced due diligence are required to provide the requested documentation promptly. Failure or refusal to provide satisfactory information results in restrictions on gambling activity or denial of access to services.
- Ongoing Monitoring
Genting Casino Reading conducts ongoing monitoring of customer transactions and behaviour throughout the customer relationship. Monitoring is not limited to initial onboarding checks and includes:
- Review of betting patterns, cash buy-ins, chip purchases, and chip redemptions.
- Identification of activity that is inconsistent with a customer’s known profile or stated circumstances.
- Reassessment of customer risk ratings in response to changes in behaviour or new information.
Where monitoring identifies activity that is unusual, inconsistent, or otherwise raises concern, appropriate steps are taken. These may include requesting additional information from the customer, restricting access to services, or filing a report with the relevant authority.
- Suspicious Activity Reporting
Where Genting Casino Reading has knowledge or reasonable suspicion that funds associated with a customer may represent the proceeds of crime or may be linked to terrorist financing, there is a legal requirement to file a Suspicious Activity Report (SAR) with the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency (NCA).
SAR filings are made in accordance with the Proceeds of Crime Act 2002 and the Terrorism Act 2000. It is prohibited by law to disclose to a customer or any third party that a SAR has been filed or that a suspicion has been formed. This obligation applies to all staff involved in the compliance process.
- Record Retention
Genting Casino Reading retains records of all KYC documentation, customer due diligence assessments, transaction records, and SAR decisions for a minimum period of five years from the date of the relevant transaction or the end of the customer relationship, whichever is later. These records are maintained in a format that allows them to be made available to the Gambling Commission, the NCA, or other competent authorities upon lawful request.
- Internal Governance and Staff Responsibilities
7.1 Money Laundering Reporting Officer
Genting Casino Reading designates a nominated officer, referred to as the Money Laundering Reporting Officer (MLRO), who holds responsibility for overseeing AML compliance on the premises. The MLRO is the designated point of contact for internal suspicious activity reports submitted by staff and is responsible for determining whether an external SAR should be filed with the UKFIU.
7.2 Staff Training
All staff at Genting Casino Reading who are involved in customer-facing roles or compliance functions receive role-appropriate training on AML and KYC obligations. Training covers the identification of suspicious activity, the application of customer due diligence procedures, and the internal reporting process. Training is conducted at induction and updated on a regular basis to reflect changes in regulation and identified risk.
7.3 Policy Review and Audit
AML and KYC policies and procedures at Genting Casino Reading are subject to periodic internal review and independent audit. Reviews are conducted to assess the effectiveness of existing controls, identify deficiencies, and implement improvements. Policy updates are made in response to changes in applicable legislation, Gambling Commission guidance, or the outcomes of internal risk assessments.
- Data Protection and Use of Personal Information
Personal data collected by Genting Casino Reading for the purposes of AML and KYC compliance is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Data collected for compliance purposes is used solely for identity verification, risk assessment, ongoing monitoring, and regulatory reporting. Customers have rights in relation to their personal data as set out in the Privacy Policy, subject to applicable legal exemptions that apply where data processing is required for compliance with a legal obligation.
- Customer Obligations and Consequences of Non-Compliance
Customers accessing gambling services at Genting Casino Reading are required to cooperate with AML and KYC procedures. This includes providing accurate information, supplying requested documentation within a reasonable timeframe, and notifying the casino of any material changes to their circumstances that may affect their risk profile.
Where a customer declines to provide required information, provides information that cannot be verified, or where documentation raises concerns that cannot be resolved, Genting Casino Reading reserves the right to restrict or terminate access to gambling services. Such decisions are made in accordance with regulatory obligations and do not constitute a discretionary commercial decision.
- Regulatory Authority
Genting Casino Reading operates under the oversight of the UK Gambling Commission. Customers who wish to raise concerns about compliance matters may contact the Gambling Commission directly via its official website at www.gamblingcommission.gov.uk.