1. Introduction and Purpose
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy of Grosvenor Casino Leo Liverpool. The purpose of this policy is to establish the procedures and obligations that govern how Grosvenor Casino Leo Liverpool identifies, verifies, monitors, and manages customers in accordance with applicable United Kingdom legislation and regulatory requirements.
Grosvenor Casino Leo Liverpool operates under the regulatory framework established by the UK Gambling Commission (UKGC) and complies with the Money Laundering Regulations 2017, the Proceeds of Crime Act 2000 (POCA), and all associated statutory instruments and guidance issued by HM Treasury and the Gambling Commission. This policy applies to all customers and all activity conducted through or at Grosvenor Casino Leo Liverpool.
2. Legal Framework
Grosvenor Casino Leo Liverpool is subject to the following primary legal and regulatory instruments:
- UK Gambling Commission licensing conditions and codes of practice
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Proceeds of Crime Act 2000
- Terrorism Act 2000 and associated counter-financing legislation
- HM Treasury guidance on financial crime risk in the gambling sector
The gambling sector is classified as high risk for money laundering and terrorist financing under the UK National Risk Assessment. Grosvenor Casino Leo Liverpool acknowledges this classification and applies controls proportionate to that risk level.
3. Risk-Based Approach
Grosvenor Casino Leo Liverpool operates a risk-based approach to AML and KYC compliance. The level of due diligence applied to any customer or transaction is determined by the assessed risk associated with that customer, their activity, and the nature of the funds involved.
A written Money Laundering Risk Assessment is maintained by Grosvenor Casino Leo Liverpool. This assessment is reviewed on a regular basis and is available for inspection by the UK Gambling Commission upon request. The risk assessment covers customer risk, product risk, geographic risk, and channel risk.
4. Customer Identification and Verification
4.1 Standard Verification Requirements
Before a customer is permitted to engage in gambling activity at Grosvenor Casino Leo Liverpool, the following information must be collected and verified:
- Full legal name
- Date of birth
- Residential address
- Government-issued photographic identification
Verification is conducted using reliable and independent documentary or electronic sources. Grosvenor Casino Leo Liverpool does not accept unverified customers for regulated gambling activity.
4.2 Age Verification
The minimum age for gambling at Grosvenor Casino Leo Liverpool is 18 years. Age verification is mandatory and is completed prior to any gambling activity being permitted. No exceptions apply.
5. Customer Due Diligence
5.1 Standard Customer Due Diligence
Standard Customer Due Diligence (CDD) is applied to all customers at the point of onboarding and is maintained on an ongoing basis. CDD includes the collection and verification of identity information as described in Section 4 and the assessment of the customer’s intended gambling activity.
5.2 Enhanced Due Diligence
Enhanced Due Diligence (EDD) is applied in the following circumstances:
- The customer is identified as a Politically Exposed Person (PEP) or a relative or close associate of a PEP
- The customer’s cumulative transactions reach or exceed the equivalent of 2,000 GBP or EUR 2,000 within a 24-hour period
- The customer’s activity or profile presents indicators of elevated money laundering or terrorist financing risk
- The customer holds a remote casino operating licence or is subject to enhanced scrutiny under applicable regulations
EDD may include, but is not limited to, verification of Source of Funds (SOF), verification of Source of Wealth (SOW), additional identity documentation, and senior management approval before the business relationship continues.
5.3 Politically Exposed Persons
Grosvenor Casino Leo Liverpool screens all customers against PEP lists, sanctions lists, and adverse media sources. Where a customer is identified as a PEP or associated with a PEP, Enhanced Due Diligence is applied automatically. Senior management approval is required before establishing or continuing a business relationship with a PEP.
6. Ongoing Monitoring
Grosvenor Casino Leo Liverpool conducts ongoing monitoring of all customer relationships. This includes:
- Review of transactions to ensure consistency with the customer’s known profile and stated source of funds
- Identification of unusual or suspicious patterns of activity, including rapid deposits and withdrawals, structured transactions designed to avoid reporting thresholds, and high-value activity inconsistent with the customer’s profile
- Periodic review and update of customer due diligence records
Where monitoring identifies activity that is inconsistent with the customer’s known profile or that raises suspicion of money laundering or terrorist financing, the matter is escalated in accordance with the procedures set out in Section 7.
7. Suspicious Activity Reporting
Grosvenor Casino Leo Liverpool maintains a designated Nominated Officer responsible for receiving internal disclosures of suspicious activity and for making Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) where required under POCA and the Terrorism Act 2000.
All staff are required to report suspicions of money laundering or terrorist financing to the Nominated Officer without delay. Tipping off a customer that a SAR has been made or is being considered is prohibited under UK law.
8. Compliance Officers and Governance
Grosvenor Casino Leo Liverpool has appointed:
- A board-level or senior management AML Compliance Officer with overall responsibility for the AML and KYC framework
- A Nominated Officer responsible for internal disclosures and SAR submissions to the NCA
The identities of both officers are notified to the UK Gambling Commission within 14 days of appointment, in accordance with regulatory requirements. The Compliance Officer is responsible for ensuring that this policy is reviewed, updated, and implemented effectively across the organisation.
9. Independent Audit
Grosvenor Casino Leo Liverpool subjects its AML and KYC controls to independent audit on a periodic basis. The purpose of the audit is to assess the effectiveness of the controls in place, identify any gaps or weaknesses, and ensure that the policy remains consistent with current regulatory requirements and guidance. Audit findings are reported to senior management and acted upon within defined timescales.
10. Staff Training
All relevant staff at Grosvenor Casino Leo Liverpool receive training on AML and KYC obligations appropriate to their role. Training covers the recognition of suspicious activity, internal reporting procedures, legal obligations under POCA and the Money Laundering Regulations 2017, and the consequences of non-compliance. Training records are maintained and made available to the Gambling Commission upon request.
11. Data Handling and Retention
Personal data collected 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. Customer records and due diligence documentation are retained for a minimum of five years from the end of the business relationship or the date of the transaction, as required by the Money Laundering Regulations 2017.
12. Credit Card Prohibition
In accordance with UK Gambling Commission requirements effective from April 2020, Grosvenor Casino Leo Liverpool does not accept credit cards as a method of funding gambling activity.
13. Policy Review
This policy is reviewed at least annually and following any material change in applicable legislation, regulatory guidance, or the risk profile of Grosvenor Casino Leo Liverpool. The most current version of this policy supersedes all previous versions.