The Gambling Commission website uses cookies to make the site work better for you. Some of these cookies are essential to how the site functions and others are optional. Optional cookies help us remember your settings, measure your use of the site and personalise how we communicate with you. Any data collected is anonymised and we do not set optional cookies unless you consent.

Set cookie preferences

You've accepted all cookies. You can change your cookie settings at any time.

Skip to main content

Guidance

The prevention of money laundering and combating the financing of terrorism

Guidance for remote and non-remote casinos: fifth edition

  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 or terrorist 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
Is this page useful?
Back to top