- Introduction and Regulatory Basis
Genting Casino Fountain Park Edinburgh operates as a licensed casino premises under the regulatory authority of the UK Gambling Commission. The premises, registered on the Gambling Commission public register as Genting Electric Fountain Park, are located at Unit F, Fountain Park, 124 Dundee Street, Edinburgh, EH11 1AF, United Kingdom. The corporate operator is Genting Casinos UK Limited, registered under account number 537 on the Gambling Commission public register, with its head office at Genting Management Office, First Floor, Resorts World Birmingham, Pendigo Way, Birmingham, B40 1PU, United Kingdom.
The premises licence is authorised by the City of Edinburgh Council as the local licensing authority. All casino operations at this venue are conducted in accordance with the Gambling Act 2005, the Proceeds of Crime Act 2002, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and applicable Gambling Commission Licence Conditions and Codes of Practice (LCCP).
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations applicable to Genting Casino Fountain Park Edinburgh, the procedures followed at the venue, and the responsibilities of patrons in connection with those obligations.
- Scope of This Policy
This policy applies to all individuals who enter or seek to participate in regulated casino activities at Genting Casino Fountain Park Edinburgh. It governs the collection, verification, and processing of customer identity information, the assessment of customer risk, and the monitoring of transactions and activity for the purpose of preventing financial crime, money laundering, and terrorist financing.
This policy does not constitute a general privacy notice. For information on how personal data is collected, processed, and retained by Genting Casinos UK Limited and its UK group companies, patrons should refer to the Genting Casinos Privacy Policy published at gentingcasinos.co.uk/privacy-policy.
- Customer Due Diligence (CDD)
3.1 Identity Verification Requirements
Genting Casino Fountain Park Edinburgh is required to identify and verify the identity of customers before permitting participation in regulated casino activities. Customer due diligence is conducted in accordance with a risk-based approach as required by applicable UK AML legislation and Gambling Commission guidance.
As part of standard customer due diligence, the venue may require patrons to provide documentation confirming the following:
- Full legal name
- Date of birth
- Residential address
Acceptable forms of identification include government-issued photographic documents such as a valid passport or driving licence, and documentary evidence of address such as a recent utility bill or bank statement. The venue reserves the right to determine the acceptability of any document presented.
3.2 Timing of Verification
Customer identity verification is conducted prior to, or at the point of, participation in regulated gaming activity. Participation in regulated casino activities is not permitted where identity verification has not been completed to the required standard.
3.3 Ongoing Due Diligence
Customer due diligence is treated as a continuous obligation. Customer activity is monitored on an ongoing basis and updated or additional documentation may be requested at any point where a change in risk profile is identified, where existing records become insufficient, or where regulatory requirements mandate a review.
- Enhanced Due Diligence (EDD)
4.1 Circumstances Requiring Enhanced Due Diligence
Enhanced due diligence is applied in circumstances where a higher level of risk is identified. This includes, but is not limited to:
- Situations where a customer places bets totalling two thousand euros or the equivalent in sterling within a twenty-four-hour period
- Situations where a customer is identified as a Politically Exposed Person (PEP) or a close associate of a PEP
- Situations where transaction patterns or customer behaviour present indicators of elevated financial crime risk
4.2 Source of Funds and Source of Wealth
Where enhanced due diligence is required, the venue may request documentation or information to establish the source of funds used for gambling activity and, where appropriate, the broader source of wealth of the customer. Participation in regulated gaming activity may be suspended or declined pending satisfactory completion of enhanced due diligence.
- Risk-Based Approach
Genting Casino Fountain Park Edinburgh applies a risk-based approach to AML and KYC compliance. Each customer is assessed individually with reference to factors including the nature and volume of their activity, their country of origin or residence, their status as a PEP or sanctioned individual, and any other indicators relevant to financial crime risk. Risk assessments are reviewed and updated as customer profiles evolve over time.
- Transaction Monitoring
The venue maintains transaction monitoring as a core component of its AML programme. Unusual or suspicious transactions are subject to internal review. Where required by law, a Suspicious Activity Report (SAR) will be filed with the National Crime Agency (NCA) in accordance with the Proceeds of Crime Act 2002. The venue is prohibited by law from disclosing to a customer that a SAR has been filed or that an investigation is underway.
- Screening Obligations
Customers are screened against relevant sanctions lists, PEP databases, and adverse media sources as part of the customer due diligence process. Screening is conducted at onboarding and on an ongoing basis. Where a match is identified, appropriate action will be taken in accordance with internal procedures and applicable legal obligations.
- Compliance Governance
8.1 Appointed Officers
Genting Casinos UK Limited appoints senior management officers responsible for AML and KYC compliance across its casino premises, including Genting Casino Fountain Park Edinburgh. A nominated officer is appointed in accordance with the requirements of the Money Laundering Regulations. The identity of the compliance officer and nominated officer is notified to the Gambling Commission within the timelines prescribed by applicable regulation.
8.2 Independent Audit
The AML and KYC programme applicable to Genting Casino Fountain Park Edinburgh is subject to independent audit. The purpose of the audit function is to assess the effectiveness of controls, identify deficiencies, and ensure that procedures remain consistent with current regulatory requirements.
8.3 Staff Training
Relevant employees at the venue receive training on AML and KYC obligations, including the identification of suspicious activity, the correct handling of customer due diligence documentation, and the internal escalation and reporting procedures applicable to financial crime concerns.
- Recordkeeping
Records relating to customer due diligence, identity verification, transaction monitoring, and suspicious activity are retained for the periods specified under applicable UK AML legislation. Retention of personal data is conducted in accordance with the Genting Casinos UK Limited Privacy Policy and applicable data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.
- Patron Obligations
Patrons of Genting Casino Fountain Park Edinburgh are required to cooperate fully with identity verification and due diligence procedures. Failure to provide requested documentation or information may result in the refusal or suspension of access to regulated gaming activity. The provision of false, misleading, or fraudulent documentation constitutes a serious breach and may be reported to relevant law enforcement authorities.
- Contact and Queries
Queries relating to identity verification or compliance procedures at Genting Casino Fountain Park Edinburgh should be directed to staff at the venue premises located at Unit F, Fountain Park, 124 Dundee Street, Edinburgh, EH11 1AF, United Kingdom. For group-level data protection and privacy enquiries, patrons should refer to the contact details provided in the Genting Casinos Privacy Policy at gentingcasinos.co.uk/privacy-policy.