1. Introduction and Scope
This document sets out the anti-money laundering (AML) and know-your-customer (KYC) framework applicable to Napoleons Casino Leeds, operated by The A & S Leisure Group Limited. The policy applies to all individuals who enter, access, or participate in gaming activities at the Leeds venue.
Napoleons Casino Leeds operates as a land-based casino and restaurant within the United Kingdom. As a UK-based gaming establishment, the venue is subject to the Gambling Act 2005, the requirements of the UK Gambling Commission, and applicable anti-money laundering legislation, including obligations arising under the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations.
The A & S Leisure Group Limited, registered at 15 Livesey Street, Sheffield S6 2BL, United Kingdom, is the corporate entity responsible for maintaining and enforcing this policy across all Napoleons Casinos and Restaurants venues, including the Leeds location.
2. Legal and Regulatory Basis
Napoleons Casino Leeds is required to maintain effective AML and KYC controls in accordance with:
- The Gambling Act 2005
- UK Gambling Commission operating licence conditions and codes of practice
- The Money Laundering, Terrorist Financing and Transfer of Funds Regulations
- The Proceeds of Crime Act 2002
- The UK Data Protection Act 2018 and 2023
- The UK General Data Protection Regulation (UK GDPR)
The UK Gambling Commission issues regulatory guidance requiring all licensed land-based casino operators to implement customer identification procedures, transaction monitoring, and suspicious activity reporting. Failure to comply with these obligations may result in regulatory action, including financial penalties.
3. Age Verification and Entry Requirements
Napoleons Casino Leeds operates a Challenge 25 policy. Any individual who appears to be under 25 years of age will be required to produce valid photographic identification before being permitted to enter the gaming areas or participate in any gambling activity.
The minimum legal age to enter and gamble at Napoleons Casino Leeds is 18 years. Entry and participation in gaming will be refused to any individual who cannot demonstrate that they meet this requirement.
Accepted forms of identification for age verification include government-issued photographic documents such as a valid passport, a photocard driving licence, or a recognised national identity card. Documents must be current and unaltered.
4. Customer Identification and KYC Procedures
4.1 Identity Verification
As part of its KYC obligations, Napoleons Casino Leeds collects and verifies personal information from customers. This process may be initiated at the point of entry, during account registration, or at any stage during a customer’s visit where compliance or security checks are required.
Personal information collected during identity verification may include full name, date of birth, residential address, and photographic identification details. This information is processed in accordance with data protection obligations under UK GDPR and the Data Protection Act 2018 and 2023.
4.2 Ongoing Due Diligence
Customer due diligence (CDD) is applied on a risk-based basis. Where a customer’s activity, transaction patterns, or profile indicates an elevated risk of money laundering or financial crime, enhanced due diligence (EDD) measures will be applied. EDD may include requests for source of funds (SOF) documentation and source of wealth (SOW) information.
Acceptable documentation for source of funds and source of wealth verification may include recent bank statements, payslips, tax returns, business ownership records, or other financial records sufficient to confirm the legitimate origin of funds used for gambling.
4.3 Non-Member Visitor Limits
Visitors who are not registered members of Napoleons Casino Leeds are subject to an operational limit. Non-members may not gamble or cash out chips or tokens in excess of £1,000 on gaming tables, roulette machines, or slot machines during a single visit. This limit forms part of the venue’s risk-based controls for non-verified visitors.
5. Transaction Monitoring and Suspicious Activity
Napoleons Casino Leeds maintains procedures for monitoring customer transactions and activity for indicators of money laundering, terrorist financing, or other financial crime. Where unusual or suspicious activity is identified, the venue is required to take appropriate action in accordance with UK legal obligations.
This may include:
- Suspending or declining to complete a transaction
- Requesting additional identification or documentation from the customer
- Filing a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) in accordance with the Proceeds of Crime Act 2002
- Declining further service to the individual until satisfactory information is provided
Customers who decline to provide required identification or documentation, or who are unable to provide satisfactory evidence of the source of their funds, may be refused service. Such incidents will be documented internally in accordance with the venue’s record-keeping obligations.
6. Data Collection and Processing for Compliance Purposes
Personal information collected during KYC and AML checks is processed by The A & S Leisure Group Limited for the following purposes:
- To verify customer identity and age
- To conduct security and compliance checks
- To administer customer records and maintain accurate documentation
- To fulfil obligations under applicable AML legislation and UK Gambling Commission requirements
- To support internal audit and regulatory reporting functions
All personal data is processed in accordance with UK GDPR and the Data Protection Act 2018 and 2023. Data is retained for the periods required by applicable law and regulatory guidance.
Customers who wish to qualify, vary, or withdraw consent in relation to the processing of their personal data, or who have concerns about how their data is being used, may contact the Data Protection Officer for The A & S Leisure Group Limited:
Email: [email protected]
Post: The A & S Leisure Group Limited, 15 Livesey Street, Sheffield S6 2BL, United Kingdom
7. Employee Training and Internal Controls
Napoleons Casino Leeds maintains internal training programmes to ensure that relevant staff are aware of their obligations under AML legislation and UK Gambling Commission requirements. This includes training on customer identification procedures, recognition of suspicious activity indicators, and the process for escalating concerns internally and to the relevant authorities.
Internal controls are reviewed on an ongoing basis to reflect changes in regulatory guidance, risk assessments, and operational requirements.
8. Policy Review
This policy is subject to periodic review by The A & S Leisure Group Limited to ensure continued compliance with applicable legislation, UK Gambling Commission requirements, and evolving AML and KYC standards. Updates to this policy will be reflected in the group’s published compliance documentation.