1. Purpose
This Anti-Money Laundering (AML) Policy outlines the measures and controls adopted by ChristChurch Casino to detect, prevent, and report money laundering and financing of terrorism, in compliance with New Zealand’s Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) and other applicable regulations.
2. Scope
This policy applies to all users, employees, contractors, and third-party service providers involved with ChristChurch Casino. It covers all aspects of customer interaction, including registration, account management, deposits, withdrawals, and gameplay.
3. What Is Money Laundering?
Money laundering is the process of disguising the origins of illegally obtained funds to make them appear legitimate. It typically involves three stages:
- Placement – Introducing illegal funds into the financial system.
- Layering – Concealing the origin through complex transactions.
- Integration – Reintroducing the laundered money as legitimate funds.
ChristChurch Casino takes proactive steps to prevent its platform from being used in any part of this process.
4. Our Commitment
ChristChurch Casino is fully committed to:
- Identifying and verifying the identity of our customers (KYC)
- Monitoring transactions for suspicious activity
- Reporting suspicious transactions to the appropriate authorities
- Training staff to recognize and respond to potential AML/CFT risks
- Cooperating with regulators and law enforcement agencies
5. Customer Due Diligence (CDD)
We perform Customer Due Diligence (CDD) on all players before allowing access to certain features, especially financial transactions.
a. Standard CDD Includes:
- Full name
- Date of birth
- Residential address
- Valid government-issued photo ID
- Proof of address (e.g., utility bill)
b. Enhanced Due Diligence (EDD):
Performed for high-risk customers, including but not limited to:
- Politically Exposed Persons (PEPs)
- Unusual deposit patterns or high-value transactions
- Users from high-risk jurisdictions
EDD may involve:
- Additional identity checks
- Source of funds verification
- Ongoing monitoring and transaction reviews
6. Ongoing Monitoring
We continuously monitor customer activity to detect:
- Irregular transaction patterns
- Rapid movement of funds in and out
- Use of multiple accounts or identities
- Suspicious gaming behavior (e.g., low-risk betting with high turnover)
If any red flags are detected, we reserve the right to:
- Request additional documentation
- Suspend or terminate accounts
- File a Suspicious Activity Report (SAR) with the New Zealand Financial Intelligence Unit (FIU)
7. Record Keeping
In accordance with legal requirements, we maintain:
- Customer identity verification records
- Transaction histories
- Correspondence and KYC data
Retention period: Minimum of 7 years from the date of the transaction or end of customer relationship.
8. Reporting Obligations
ChristChurch Casino is obligated to report the following to New Zealand’s FIU:
- Suspicious Activity Reports (SARs)
- Large cash transactions (NZD $10,000 or more)
- International fund transfers
Reports are made without notifying the customer involved (tipping-off is strictly prohibited).
9. Employee Training
All employees undergo regular training to ensure they:
- Understand AML/CFT laws and obligations
- Recognize suspicious behavior and red flags
- Know how and when to escalate a concern
- Are aware of the internal reporting procedures
10. Risk-Based Approach
ChristChurch Casino adopts a risk-based approach to AML/CFT compliance. This includes:
- Assessing risk by customer profile, behavior, and geography
- Applying controls proportionate to the risk level
- Reviewing and updating our risk assessments regularly
11. Internal Controls
To ensure compliance, ChristChurch Casino maintains:
- An AML Compliance Officer (CO) responsible for policy enforcement
- Independent audits of AML procedures
- Regular updates to systems and training
- Strong data protection and access controls
12. Breach of Policy
Any employee or customer found violating this policy or attempting to misuse the platform for illegal financial activities will face:
- Immediate suspension of access
- Investigation and internal review
- Reporting to appropriate law enforcement agencies
13. Policy Review
This AML Policy is reviewed annually or whenever there is a change in legislation, risk exposure, or operational procedures. All updates will be documented and communicated internally.
14. Contact
If you have questions about this AML Policy or need to report a concern, please contact:
ChristChurch Casino – AML Compliance Team
Email: [email protected]
Address: 101 West Plains Road, West Plains 9874, New Zealand
