- Introduction
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by Napoleons Casino Bradford. It defines the obligations of the establishment and the requirements placed on customers in connection with identity verification, customer due diligence, transaction monitoring, and the reporting of suspicious activity.
Napoleons Casino Bradford operates in accordance with applicable United Kingdom legislation and the licensing conditions issued by the UK Gambling Commission. The establishment is required to maintain adequate controls to prevent its premises and services from being used for money laundering or the financing of terrorism.
This policy applies to all customers who seek to open an account, access gambling facilities, or conduct financial transactions with Napoleons Casino Bradford.
- Legal Framework
Napoleons Casino Bradford conducts its compliance activities in accordance with the following regulatory framework:
- The Proceeds of Crime Act 2002
- The Terrorism Act 2000
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended
- UK Gambling Commission Licence Conditions and Codes of Practice
- Financial Action Task Force recommendations as adopted under UK law
The UK Gambling Commission has a statutory duty to ensure that gambling businesses maintain adequate controls against money laundering and terrorist financing. Napoleons Casino Bradford accepts and fulfils this duty as a condition of its operating licence.
- Know Your Customer Requirements
3.1 Identity Verification
Napoleons Casino Bradford requires all customers to verify their identity before being permitted to gamble or conduct financial transactions. Verification must be completed at the point of account registration or, for non-remote access, before participation in gambling activities.
Acceptable documents for identity verification include:
- Valid passport
- UK driving licence (full or provisional)
- National identity card issued by a recognised authority
3.2 Age Verification
No customer under the age of 18 will be permitted to gamble. Age verification is a mandatory step in the onboarding process. Where age cannot be confirmed, access to gambling will be suspended until verification is completed.
3.3 Address Verification
Customers are required to provide proof of residential address. Acceptable documents include a recent utility bill, bank statement, or official correspondence issued within the preceding three months.
3.4 Source of Funds and Source of Wealth
Where a customer’s transaction activity, deposit levels, or betting patterns indicate elevated risk, Napoleons Casino Bradford will request documentation to verify the source of funds and, where applicable, the source of wealth. This may include payslips, bank statements, tax returns, or other financial records. Gambling activity will be restricted until satisfactory documentation is received and assessed.
- Customer Due Diligence
4.1 Standard Due Diligence
Standard customer due diligence is applied to all customers at the point of onboarding. This includes identity verification, age verification, and address confirmation as described in Section 3.
4.2 Enhanced Due Diligence
Enhanced due diligence is applied where a customer presents a higher level of risk. Circumstances that may trigger enhanced due diligence include:
- The customer is identified as a politically exposed person or a close associate of one
- Transaction volumes or patterns are inconsistent with the customer’s stated profile
- The customer is resident in or connected to a high-risk jurisdiction
- Adverse media or sanctions screening returns a relevant result
- Source of funds or source of wealth cannot be established through standard means
Enhanced due diligence may involve additional document requests, extended review periods, and senior management approval before access is restored or continued.
4.3 Ongoing Monitoring
Customer accounts and transaction activity are subject to ongoing monitoring throughout the customer relationship. Monitoring includes review of transaction frequency, deposit and withdrawal volumes, changes in betting behaviour, and any new information that may affect the customer’s risk classification.
Risk classifications are reviewed periodically and updated when new information becomes available.
- Transaction Monitoring
Napoleons Casino Bradford applies automated and manual controls to monitor financial transactions. Transactions that are unusually large, structured in a manner that appears designed to avoid reporting thresholds, or otherwise inconsistent with a customer’s known profile will be flagged for review.
Where a transaction cannot be satisfactorily explained, it will be escalated to the designated compliance function for further assessment.
- Suspicious Activity Reporting
Where Napoleons Casino Bradford has knowledge, suspicion, or reasonable grounds for suspicion that a transaction or activity is connected to money laundering or terrorist financing, a Suspicious Activity Report will be submitted to the National Crime Agency in accordance with the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
Customers will not be informed that a report has been made or that an investigation is underway. Disclosure of such information to a customer constitutes a criminal offence under applicable UK legislation.
- Recordkeeping
Napoleons Casino Bradford retains records of customer identification documents, due diligence assessments, transaction histories, and compliance decisions for a minimum period of five years from the end of the customer relationship or the date of the relevant transaction, whichever is later. Records are maintained in a format that allows retrieval upon request by the UK Gambling Commission or other competent authority.
- Politically Exposed Persons
Customers identified as politically exposed persons, or as immediate family members or known close associates of such persons, are subject to enhanced due diligence as a minimum. Senior management approval is required before establishing or continuing a business relationship with a politically exposed person. The source of funds and source of wealth of such customers must be established and documented.
- Sanctions Screening
All customers are screened against applicable sanctions lists at the point of onboarding and on an ongoing basis. Customers who appear on a sanctions list will have their account suspended immediately. Napoleons Casino Bradford will not conduct transactions with sanctioned individuals, entities, or jurisdictions.
- Customer Obligations
Customers are required to:
- Provide accurate and complete information at the point of registration and upon request
- Submit requested documentation within the timeframe specified by Napoleons Casino Bradford
- Notify Napoleons Casino Bradford of any material change in their circumstances that may affect their compliance status
- Cooperate with any due diligence or verification request
Failure to comply with these obligations will result in restriction or closure of the customer account and may result in the withholding of funds pending investigation.
- Policy Review
This policy is reviewed at least annually and updated as required to reflect changes in applicable legislation, regulatory guidance, or internal risk assessments. The current version of this policy is available upon request.