1. Introduction
Skycity Casino (“the Company”, “we”, “our”, or “us”) is committed to preventing all forms of money laundering, terrorism financing, and other financial crimes. We have implemented a robust Anti-Money Laundering (AML) Policy to ensure compliance with the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) in New Zealand, along with global standards set by the Financial Action Task Force (FATF).
This Policy outlines our procedures for identifying, reporting, and mitigating money laundering risks.
2. Purpose
The purpose of this AML Policy is to:
- Prevent the use of Skycity Casino’s services for money laundering or terrorist financing.
- Comply with all relevant local and international AML regulations.
- Establish internal controls and procedures to detect suspicious activity.
- Maintain a culture of compliance and accountability across all departments.
- Protect the integrity and reputation of Skycity Casino.
3. Definitions
- Money Laundering: The process of disguising the origins of illegally obtained money to make it appear legitimate.
- Terrorist Financing: The act of providing funds for terrorist activities, regardless of whether the source is lawful or unlawful.
- KYC (Know Your Customer): A process of verifying a customer’s identity and assessing potential risk.
- PEP (Politically Exposed Person): An individual who holds or has held a prominent public position and may be exposed to corruption risks.
4. Customer Due Diligence (CDD)
We perform varying levels of Customer Due Diligence based on the customer’s risk profile.
a. Standard CDD
Performed for all users upon registration and includes:
- Full legal name
- Date of birth
- Residential address
- Valid photo ID (passport, driver’s license, or national ID)
- Proof of address (utility bill, bank statement, etc.)
b. Enhanced Due Diligence (EDD)
Applied when:
- A customer makes large or unusual transactions
- A customer is identified as a PEP
- There is reason to suspect a higher risk of money laundering or terrorism financing
Additional information may be required, including:
- Source of funds
- Source of wealth
- Occupation/employer information
- Additional documentation or video verification
5. Ongoing Monitoring
Skycity Casino conducts continuous monitoring of customer activity to detect and report suspicious transactions. This includes:
- Tracking deposit and withdrawal patterns
- Monitoring gaming activity for anomalies
- Reviewing documentation regularly
- Re-verifying identity information when required
6. Suspicious Activity Reporting
If any employee or system detects potentially suspicious activity, it must be reported immediately to our AML Compliance Officer.
Examples of suspicious behavior:
- Attempts to deposit or withdraw large sums without clear purpose
- Reluctance to provide requested documentation
- Structuring transactions to avoid reporting thresholds
- Use of multiple accounts or aliases
- Unusual patterns inconsistent with a customer’s profile
Such activities are documented and, if necessary, reported to the New Zealand Financial Intelligence Unit (FIU) or other relevant authorities.
7. Record Keeping
In accordance with regulatory requirements, we retain the following for a minimum of seven (7) years:
- Customer identity documentation
- Transaction histories
- Records of suspicious activity reports (SARs)
- Internal and external communication related to AML procedures
All data is stored securely with restricted access.
8. Staff Training
Skycity Casino ensures that all relevant employees receive regular AML training, including:
- AML legislation and responsibilities
- Detecting suspicious activity
- Proper documentation and escalation procedures
- KYC/EDD obligations
- Confidentiality and data handling
Training is mandatory and regularly updated.
9. Risk Assessment
We maintain a Risk-Based Approach (RBA) to identify and assess risks associated with:
- Types of customers
- Geographic locations
- Services and delivery channels
- Transaction behaviors
Risk assessments are reviewed and updated periodically.
10. Compliance Officer
Skycity Casino has appointed a dedicated AML Compliance Officer, responsible for:
- Overseeing AML program implementation
- Conducting internal audits
- Receiving and investigating suspicious activity reports
- Liaising with regulatory and law enforcement bodies
- Keeping AML policies and procedures up to date
The AML Compliance Officer operates independently and has full access to necessary data and systems.
11. Prohibited Transactions
We strictly prohibit:
- Anonymous or pseudonymous accounts
- Use of third-party or proxy payment methods
- Transactions involving jurisdictions or entities under international sanctions
- Cryptocurrency transactions (if not explicitly supported under our regulated framework)
12. Cooperation with Authorities
Skycity Casino cooperates fully with all relevant law enforcement, regulatory, and government authorities. We may, without prior notice, disclose personal and transaction data if required by law or court order.
13. Policy Review
This AML Policy is reviewed at least annually, or whenever significant regulatory changes occur. Revisions will be approved by senior management and communicated to relevant staff and departments.
14. Contact Information
For any questions regarding this AML Policy, or to report suspicious activity, please contact:
📍 Skycity Casino
45 Tyne Street
Invercargill 9810
New Zealand
