- Purpose and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applied by The Colony Club to all customers accessing gambling services in the United Kingdom. The policy establishes procedures designed to prevent money laundering, terrorist financing, and other forms of financial crime in connection with the operation of the service.
The Colony Club holds a licence issued by the UK Gambling Commission (UKGC). As a licensed operator, the company is legally required to comply with the following legislation and regulatory frameworks:
- Proceeds of Crime Act 2002 (POCA)
- Terrorism Act 2000
- Gambling Act 2005
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- UK Gambling Commission Licence Conditions and Codes of Practice (LCCP), specifically Condition 12.1.1
This policy applies to all account holders at the point of registration, throughout the account lifecycle, and at any stage where a risk-based review is required.
- Obligations Under LCCP Condition 12.1.1
Under Licence Condition 12.1.1, The Colony Club is required to:
- Conduct and document a business-wide risk assessment of money laundering and terrorist financing risks relevant to its operations.
- Implement policies, procedures, and controls proportionate to the risks identified in that assessment.
- Ensure those controls are effectively applied, regularly reviewed, and updated in response to changes in products, customer demographics, payment methods, technology, and Gambling Commission guidance.
The business-wide risk assessment and associated controls are reviewed on a regular basis and updated in line with the Gambling Commission’s published industry risk assessments, including the 2026 assessment of money laundering and terrorist financing risks within the British gambling industry.
- Customer Due Diligence (CDD)
3.1 Standard CDD Requirements
Customer Due Diligence is applied at account opening and at defined points during the customer relationship. CDD measures at The Colony Club include:
- Identifying the customer by collecting personal information including full name, date of birth, and residential address.
- Verifying the customer’s identity using documents or information from a reliable, independent source.
- Identifying any beneficial owner where applicable and taking reasonable steps to verify their identity.
- Assessing the purpose and intended nature of the customer’s use of the services where this is not self-evident.
3.2 Threshold-Based Triggers
In line with Gambling Commission guidance, a threshold approach is applied to trigger identity verification and CDD checks. For remote casino operations, CDD is required when a customer deposits or withdraws funds or winnings amounting to €2,000 or more. These thresholds do not replace risk-based monitoring; they represent minimum trigger points. CDD may be applied at lower values where risk indicators are present.
3.3 Third-Party Representatives
Where a person claims to act on behalf of a customer, the following measures are applied:
- Verification that the person is authorised to act in that capacity.
- Identification of that person.
- Verification of their identity using documents or information from a reliable, independent source.
Instructions from unverified third parties in relation to a customer’s account are not accepted.
- Enhanced Due Diligence (EDD) and Enhanced Ongoing Monitoring
Enhanced Due Diligence applies in higher-risk situations. The Colony Club applies EDD and enhanced ongoing monitoring where:
- A customer is identified as a Politically Exposed Person (PEP) or a close associate or family member of a PEP.
- A customer’s transactional or behavioural profile presents elevated risk indicators.
- The product type, technology, or payment method used is associated with higher money laundering or terrorist financing risk.
- A customer’s activity triggers internal risk flags outside normal patterns.
EDD may involve requesting additional documentation, conducting source of funds or source of wealth checks, or applying more frequent monitoring intervals. Financial thresholds are not relied upon in isolation when determining whether EDD is required. Risk factors including customer profile, transaction patterns, and product risk are assessed together.
- Ongoing Monitoring
The Colony Club monitors customer accounts and transactions on a continuous basis throughout the customer relationship. Monitoring includes:
- Reviewing transactions to assess whether they are consistent with the customer’s known profile and stated purpose.
- Identifying unusual or suspicious patterns of activity.
- Screening customers against sanctions lists and PEP databases at onboarding and on an ongoing basis.
- Updating customer information and risk classifications when material changes occur.
Where monitoring identifies activity that is inconsistent with a customer’s profile or that raises suspicion of financial crime, appropriate action is taken. This may include requesting further information, restricting account activity, or filing a Suspicious Activity Report (SAR) with the relevant authority.
- Electronic Verification
Electronic verification methods are used to confirm customer identity as part of the KYC process. Customers are informed that electronic identity checks will be conducted. These checks do not require explicit customer consent for AML and counter-terrorist financing purposes under applicable UK law, but customers are notified that such checks form part of standard account procedures.
Electronic verification does not replace the obligation to apply judgement and a risk-based assessment. Where electronic checks are inconclusive or where risk indicators are present, documentary evidence of identity may be requested.
- Internal Controls and Governance
The Colony Club maintains documented internal controls to support the effective implementation of this policy. These controls include:
- A nominated officer (Money Laundering Reporting Officer, MLRO) responsible for receiving internal suspicious activity reports and making decisions on external reporting.
- Defined internal reporting channels for staff to escalate concerns.
- Regular staff training on AML and KYC obligations, risk indicators, and reporting procedures.
- Independent audit of AML and KYC controls.
- Systems capable of identifying and mitigating money laundering, terrorist financing, and proliferation financing risks.
AML and KYC responsibilities are not delegated to third-party payment processors or partners. Responsibility for compliance with this policy remains with The Colony Club at all times.
- Age Verification
As part of the KYC process, the company verifies that all customers are of legal age to gamble before they are permitted to use the services. Age verification is conducted at the point of account registration. No gambling activity is permitted until age verification is completed and confirmed.
- Responsible Gambling Integration
AML and KYC monitoring is integrated with responsible gambling obligations. Monitoring of customer activity includes assessment of behavioural indicators that may suggest financial vulnerability, excessive spending, or problem gambling. Where such indicators are identified, appropriate risk-based interventions are applied in accordance with the Responsible Gambling Policy.
- Policy Review
This policy is reviewed at least annually and updated as required following changes to applicable legislation, Gambling Commission guidance, the product or service offering, or the results of the business-wide risk assessment. Customers may be subject to additional checks at any point where a review of their account is required under this policy.
For questions relating to identity verification or account checks, customers may contact the support team using the contact details provided in the Contact Us section of the website.