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The prevention of money laundering and combating the financing of terrorism

Gambling Commission guidance for remote and non-remote casinos: Fifth edition (Revision 3).

  1. Contents
  2. Part 7 - Record keeping
  3. 1 - General legal and regulatory requirements

1 - General legal and regulatory requirements

This chapter provides guidance on appropriate record-keeping procedures required by the Regulations. The purpose of the record-keeping requirement is to ensure that there is an audit trail that could assist in any financial investigation by a law enforcement body. These records are also important when the Commission is conducting an investigation for compliance purposes.

The casino operator’s record-keeping policy and procedure should cover records in the following areas:

  • details of how compliance has been monitored by the nominated officer
  • delegation of AML/CTF tasks by the nominated officer
  • nominated officer reports to senior management
  • information or other material concerning possible money laundering, terrorist financing or proliferation financing not acted upon by the nominated officer, with reasoning why no further action was taken
  • customer identification and verification information
  • supporting records in respect of business relationships
  • employee training records
  • internal and external SARs, including decisions and actions taken by the nominated officer
  • contact between the nominated officer and law enforcement or the NCA, including records connected to requests for a defence (appropriate consent).

The policy and procedure for record keeping should also make provision for the retention of records held by an employee who leaves the business.

The record-keeping requirements for supporting records, that is, the records of ongoing transactions with a customer, are based on the nature of the relationship with that customer. There is either:

  • no relationship, or
  • a 'business relationship', depending on the circumstances.
Next section
Business relationships
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