NOTIFICATION OF ENHANCED DUE DILIGENCE REQUIREMENTS
Changes within our industry relating to both Anti-MoneyLaundering (AML) and Know Your Customer (KYC) require us to apply rigorousenhanced due diligence for all new, existing and returning customers and theirguests, where the value of their gaming transactions exceed certain thresholds.
We are placing greater emphasis on obtaining specificinformation from our customers with regards to their source of funds (SOF) andsource of wealth (SOW), with which many members may already be familiar. The information provided must also be able tobe independently evidenced.
The Ritz Club has always set very high standards in allaspects of our business, and in particular compliance. It is important for usto maintain a fully compliant business both in the eyes of our members and ourregulator.
Whilst it is not our desire or intention to be intrusive,you may be asked to provide evidence of your source of wealth (SOW) and sourceof funds (SOF) by a member of staff.Please be assured that we will exercise complete discretion whenconducting these conversations, and treat your personal information with thestrictest of confidence.
The Gambling Commission’s Licence Conditions and Codes ofPractice (LCCP) clearly outline the expectations and requirements thatoperators must fulfil in order to protect and prevent their gambling facilitiesfrom being used for money laundering, terrorist financing, or the proceeds ofcrime.
We appreciate your understanding and co-operation and haveprovided a FAQ guideline to assist and further explain these necessaryrequirements.
FREQUENTLY ASKED QUESTIONS
Q: Why is there a need for Enhanced Due Diligence checks?
A: As a casino operator we have a responsibility to upholdthe licensing objectives set out in the Gambling Act 2005 (the Act). The first of those licensing objectives is toprevent gambling being a source of crime or disorder, being associated withcrime or disorder, or being used to support crime. We are also obliged to meetrequirements as set out by our regulator, the Gambling Commission of GreatBritain, and other applicable legislation; EU Forth Anti-Money LaunderingDirective 2015/849 and the Proceeds of Crime Act (2002).
The license conditions mandate all casino operators toundertake risk assessments and ensure they have appropriate procedures andpolicies in place to prevent their gambling facilities from being used formoney laundering, terrorist financing, or accepting the proceeds of criminalactivity.
Given that we have the responsibility to prevent gamblingfrom being associated with crime and disorder and protecting vulnerable peoplefrom being harmed by gambling, we need to carry out appropriate enquiries andassessments.
It is important that we are able to continually access andunderstand information relating to gambling activity by our valued customers,so that we have a fuller picture of the risks to which we are exposed.
Q: What kind of information will members and guests be askedto provide?
A: We will need to ask you to provide the following:-
• Verificationof your nationality and identity, such as a passport, driving licence or othergovernment-issued ID
• Proof ofresidential address
• Thenature of your business or occupation, and the jurisdiction under which thebusiness is registered
• You maybe required to provide detailed information concerning your source of funds andsource of wealth which will also need to be independently evidenced. We may, onoccasion, request documentary evidence from you.
• Otherfinancial information such as your intended level of play, memberships of othercasinos and facilities that have been extended to you.
* Please be assured that we are committed to ensuring thatyour information is secure. In order to prevent unauthorised access ordisclosure, we have put in place appropriate technical and organisationalmeasures to safeguard and secure the information we collect.
Q: When will members and guests be required to provide thisinformation?
A: Ideally theinformation should be provided before your first visit, and your ability toprovide the information requested in advance of your visit will allow us to facilitateyour requested level of play. However,should we only be provided with this information during your visit, pleaseallow sufficient time for your request to be processed.