The prevention of money laundering and the financing of terrorism
7.11 In relation to the evidence of a customer’s identity, casino operators must keep a copy of any documents or information obtained to satisfy the CDD measures required under the Regulations (regulation 40(2)).
7.12 A casino operator may often hold additional information beyond identity in respect of a customer for the purposes of wider CDD. As a matter of best practice, this information and any relevant documents should also be retained.
7.13 There is a separate requirement in the Regulations to ensure that documents, data or information held by casinos are kept up to date (regulation 28(11)) A trigger event for refreshing and extending CDD may be if a customer returns to a casino after a period of non-attendance. Refreshing information about existing customers will ensure that matters such as change of address, or a customer being appointed into a role which attracts PEP status, will be picked up. Keeping information up to date is also a requirement under the Data Protection Act. How these issues which will be dealt with in practice should be covered in the casino’s policies, procedures and controls.
7.14 Where documents verifying the identity of a customer are held in one casino premises they do not also need to be held in duplicate form in another premises in the same group. For the purposes of compliance with the Regulations the whole group forms part of the same ‘relevant person’. The records need to be accessible to all premises that have contact with the customer, the nominated officer and law enforcement. The Regulations accept that casino operators may have more than one casino premises or more than one remote casino site. It is sufficient for the operator to undertake identification and verification providing that the information is available to each premises or site.
Next chapter: Supporting records (non-remote casinos)