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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 6 - Customer due diligence
  3. 13 - Documentary evidence

13 - Documentary evidence

If verification is undertaken using documents, casino operators should usually rely upon documents issued by an authoritative source that can be assessed against official and published guidance on identity documents.

Original documents should be examined so that, as far as reasonably practicable, forgeries are not accepted. Casino operators should recognise that some documents are more easily forged than others. If suspicions are raised in relation to any document offered, operators should take whatever practical and proportionate steps are available to establish whether the document offered is a forgery or has been reported as lost or stolen. While the presentation of false documents does not, in itself, amount to money laundering, it may constitute an offence under the Fraud Act 2006 (opens in a new tab) or Identity Cards Act 2006 (opens in a new tab) and should, in appropriate circumstances, be reported to the police or the NCA.

Casino operators should also be aware that even if documents appear to be legitimate and issued by a government department they may be false

For example, the following fake documents which are freely available through the internet:

  • European Driving Permits
  • International Drivers Licences and
  • National Identity Cards.

Commercial software is available that checks the algorithms used to generate passport numbers. This can be used to check the validity of passports of any country that issues machine-readable passports.

If documents are in a foreign language, appropriate steps should be taken to be reasonably satisfied that the documents in fact provide evidence of the customer’s identity. For example, a translation of the relevant sections.

Documentation purporting to offer evidence of identity may come from several sources

These documents differ in their integrity, reliability and independence. Some are issued after CDD on the holder of the document is carried out by the issuing authority. There is a broad hierarchy of documents.

Documents issued by government departments and agencies that contain a photograph may be considered reliable. In practical terms, for face-to-face verification conducted by non-remote casinos, production of a valid passport or photo card driving licence should enable most individuals to meet the identification requirement for AML/CTF purposes. These documents will also confirm either residential address or date of birth.

Alternatively, documents from an authoritative source without a photograph which incorporate the customer’s full name may be used, supported by a second document, which is issued by an authoritative source, or issued by a public sector body or authority. This second document must also include the customer’s full name and either their residential address or their date of birth.

The following sources may be useful for verification of UK-based customers:

  • current signed passport
  • birth certificate
  • current photo card driving licence
  • current EEA member state identity card
  • current identity card issued by the Electoral Office for Northern Ireland
  • residence permit issued by the Home Office
  • firearms certificate or shotgun licence
  • benefit book or original notification letter from the Department of Works and Pensions confirming the right to benefits
  • council tax bill
  • utility bill or statement that can, on a risk basis, be verified as true by the company that issued it, commonly by confirmation of a reference number, name and address, or a certificate from a utilities supplier confirming an arrangement to pay services on pre-payment terms
  • bank, building society or credit union statement or passbook containing current address that can, on a risk basis, be verified as true by the company that issued it, commonly by confirmation of a reference number, name and address - bank or credit cards alone will not be sufficient as these do not provide either residential address or date of birth.

Wherever the following type of evidence is used, adopting a risk-based approach, you may consider confirming these sources as valid by checking with the issuing authority:

  • confirmation from an electoral register that a person of that name lives at that address
  • recent original mortgage statement from a recognised lender
  • solicitor’s letter confirming recent house purchase or land registry confirmation of address
  • local council or housing association rent card or tenancy agreement
  • HMRC self-assessment statement or tax demand
  • house or motor insurance certificate.

Customers who are not resident in the UK should be asked to produce their passport, national identity card or photo card driving licence. If the casino has concerns that the identity document presented by a customer is not genuine, they should contact the relevant embassy or consulate.

Confirmation of the customer’s address can be obtained from:

  • an official overseas government source
  • a reputable directory of addresses
  • a person regulated for money laundering purposes in the country where the customer is resident (for example, a casino or bank) who confirms that the customer is known to them and lives or works at the overseas address supplied.

Good practice

Non-remote casinos have adopted the practice of photographing new customers on their first visit to the casino as part of the CDD records. Doing so assists with casino security issues and with customer tracking. It is a matter for each casino operator, but the Commission views the use of customer photographs as good practice in the casino environment that contributes to the prevention and detection of money laundering and terrorist financing.

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Criteria for use of an electronic verification provider
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Politically exposed persons (PEPs)
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