- Introduction and Purpose
The Colony Club operates as a land-based casino in the United Kingdom and is subject to the full scope of UK anti-money laundering and counter-terrorist financing legislation. This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy that governs how The Colony Club identifies customers, assesses risk, monitors activity, and fulfils reporting obligations under applicable law.
The Colony Club is classified as a “relevant person” under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). As such, the company is legally required to maintain written policies, controls, and procedures designed to prevent its premises and services from being used for money laundering or terrorist financing.
This policy applies to all customers, staff, and third parties who interact with The Colony Club in any capacity that falls within the scope of regulated gambling activity.
- Legal and Regulatory Framework
The Colony Club’s AML and KYC obligations derive from the following primary legislative instruments and regulatory frameworks:
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Proceeds of Crime Act 2002
- Terrorism Act 2000
- Anti-Terrorism, Crime and Security Act 2001
- Counter-Terrorism Act 2008
- Gambling Commission AML guidance for licensees and businesses
Oversight of compliance with these obligations is exercised by the UK Gambling Commission. The company is required to demonstrate that its AML controls are risk-based, documented, regularly reviewed, and effectively implemented across all relevant operational areas.
- Governance and Responsibility
The Colony Club has appointed a Money Laundering Reporting Officer (MLRO) who holds primary responsibility for AML and KYC compliance within the organisation. The MLRO is responsible for:
- Receiving and evaluating internal suspicious activity reports from staff
- Determining whether a Suspicious Activity Report (SAR) must be submitted to the National Crime Agency (NCA)
- Maintaining oversight of the AML and KYC programme
- Liaising with the Gambling Commission and other relevant authorities as required
Senior management of The Colony Club is responsible for ensuring that AML controls are adequately resourced, effectively implemented, and subject to ongoing review. Responsibility for compliance does not rest solely with the MLRO; all relevant staff share an obligation to apply the procedures set out in this policy.
4. Customer Due Diligence
4.1 Standard Customer Due Diligence
The Colony Club applies Customer Due Diligence (CDD) to all customers in accordance with the requirements of the MLR 2017 and Gambling Commission guidance. Standard CDD requires the company to:
- Identify the customer and verify their identity using reliable, independent documentary evidence
- Identify any person acting on behalf of the customer and verify that they are authorised to do so
- Identify the beneficial owner where applicable and take reasonable steps to verify their identity
- Assess the nature and purpose of the customer relationship and conduct ongoing monitoring
For individual customers, acceptable identity documents include a valid UK passport or a valid UK driving licence. Proof of address is required in the form of a recent utility bill, bank statement, or equivalent document issued within the preceding three months.
4.2 Enhanced Due Diligence
Enhanced Due Diligence (EDD) is applied in circumstances where a higher level of risk has been identified. This includes, but is not limited to:
- Customers identified as Politically Exposed Persons (PEPs) or close associates of PEPs
- Customers from or transacting with higher-risk jurisdictions as defined by applicable guidance
- Transactions or patterns of play that are inconsistent with the customer’s known profile
- Situations where the source of funds or source of wealth requires clarification
Where EDD is triggered, The Colony Club will obtain additional information regarding the customer’s source of funds and source of wealth before proceeding. The company reserves the right to suspend or restrict access to its services pending satisfactory completion of EDD.
4.3 Corporate and Business Customers
Where a customer is a corporate entity or acts on behalf of a business, KYC requirements extend to:
- Company incorporation documents and evidence of legal existence
- Identification and verification of the ultimate beneficial owners (UBOs) holding a qualifying interest
- Documentation of the ownership and control structure
- Understanding of the nature of the business and its activities
- Ongoing Monitoring
The Colony Club conducts continuous monitoring of customer activity throughout the duration of the customer relationship. This includes scrutiny of transactions and patterns of play to identify activity that is inconsistent with the customer’s known profile, risk classification, or stated source of funds.
Where anomalies are identified, these are escalated internally for review. Monitoring records are maintained in accordance with applicable data retention requirements.
- Screening Obligations
All customers are screened against relevant sanctions lists, including those maintained by the United Nations, the Office of Foreign Assets Control (OFAC), and the European Union. Customers are also checked against PEP databases and adverse media sources as part of the risk assessment process.
Screening is conducted at the point of onboarding and on an ongoing basis to reflect changes in a customer’s risk profile or status.
- Suspicious Activity Reporting
All staff at The Colony Club are required to report any knowledge or suspicion of money laundering or terrorist financing to the MLRO through the internal reporting process. The MLRO will assess each report and, where appropriate, submit a SAR to the National Crime Agency in accordance with the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
Staff must not disclose to the customer or any third party that a report has been made or that an investigation is under way. Such disclosure may constitute the criminal offence of tipping off.
- Staff Training
The Colony Club provides regular AML and KYC training to all staff whose roles involve customer interaction or compliance functions. Training covers the identification of red flags, internal reporting procedures, legal obligations, and the consequences of non-compliance. Training records are maintained and made available to the Gambling Commission upon request.
- Record Keeping
The Colony Club retains records of all customer identification documents, due diligence measures, transaction records, and internal reports for a minimum period as required by the MLR 2017. These records are stored securely and are accessible to the MLRO and senior management for audit and regulatory purposes.
- Policy Review
This policy is reviewed on a regular basis to ensure it remains consistent with current legislation, Gambling Commission guidance, and the risk environment in which The Colony Club operates. Updates are communicated to relevant staff and implemented without delay.