Official compliance framework for customer verification and financial crime prevention.

Flamingo Casino AML / KYC Policy

This Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applies to all customers and all transactions conducted at Flamingo Casino. As a licensed casino operating in South Africa, Flamingo Casino is classified as an accountable institution under the Financial Intelligence Centre Act (FICA) and is required to apply risk-based controls to prevent money laundering, terrorist financing, and other financial crimes. This policy sets out the applicable legal and regulatory obligations, the procedures applied by the casino, and the requirements imposed on customers when using the casino facilities.

1. Legal Framework and Regulatory Obligations

Flamingo Casino operates under the regulatory oversight of the Northern Cape Gambling Board and is subject to national legislation, including the Financial Intelligence Centre Act, the National Gambling Act, and applicable provincial gambling regulations.

Under FICA, accountable institutions are obliged to:

Identify and verify the identity of customers in specified circumstances.
Conduct ongoing due diligence and monitor customer transactions.
Maintain records of customer information and transactions for the statutory minimum period.
Report suspicious transactions and prescribed cash transactions to the Financial Intelligence Centre (FIC).
Implement internal controls, staff training, and independent compliance audits.

The AML and KYC procedures applied at Flamingo Casino are designed to meet these legal requirements and are subject to regular review by internal compliance officers and external auditors appointed by the relevant gambling authority.

2. Customer Identification and Verification

Customer identification and verification are required before certain transactions are processed or business relationships are entered into. Identity verification is mandatory in, but not limited to, the following circumstances:

Cash transactions (buy-ins, payouts, or exchanges) above the threshold prescribed by FICA and the internal risk assessment of the casino.
Enrolment in player loyalty or rewards programmes that involve account facilities or stored value.
Cheque cashing or the use of other non-cash payment instruments.
Any transaction or pattern of activity that triggers internal risk indicators.

Acceptable forms of identification include a valid South African identity document, passport, or other government-issued photo identification recognised under South African law. Proof of residential address may also be requested. In higher-risk cases, additional information regarding the source of funds or wealth may be required.

Customers who are unable or unwilling to provide the required identification and supporting information will not be permitted to complete the relevant transaction or to access the related service.

3. Enhanced Due Diligence

Certain customers and transactions are subject to enhanced due diligence measures, based on risk factors identified in the internal risk assessment of Flamingo Casino. Enhanced due diligence applies, among other situations, to:

Foreign nationals and non-residents, particularly those from jurisdictions identified as higher risk by the FIC or international bodies.
Customers conducting high-value or high-frequency cash transactions that appear inconsistent with their known profile.
Politically exposed persons (PEPs) and their known associates or family members.
Transactions involving third parties or beneficial owners whose identity is unclear or insufficiently verified.

Enhanced due diligence may include:

Additional identity verification steps.
Requests for supporting documentation, such as bank statements, tax records, or employment verification.
Approval by senior management or by the designated Money Laundering Reporting Officer before a transaction is completed or a relationship is continued.

4. Ongoing Monitoring and Transaction Reporting

Customer activity is monitored on an ongoing basis to identify unusual or potentially suspicious patterns. Monitoring systems and staff training at Flamingo Casino are designed to detect, among other indicators:

Large cash buy-ins followed by minimal gaming activity and immediate cash-out.
Structuring of transactions to avoid reporting thresholds.
Use of multiple identification documents or inconsistent personal information.
Transactions that do not align with the customer’s known economic profile or stated purpose.

When a transaction or pattern of behaviour meets the criteria for a suspicious transaction report (STR) or a prescribed cash transaction report, a report must be filed with the Financial Intelligence Centre in accordance with applicable law. Customers are not informed when such reports are filed, and staff are prohibited from disclosing the existence or content of any report, a prohibition commonly referred to as the ban on “tipping off”.

5. Record Keeping

Records relating to customer identification, verification, and transactions are retained for at least the minimum periods prescribed by FICA and any regulations issued by the FIC. Current statutory retention periods require that:

Copies of identification documents and verification records be retained for at least five years after the business relationship ends or the transaction is completed.
Records of all transactions, including cash transactions, account activity, and relevant correspondence, be retained for at least five years.

Records are stored in a secure manner and are accessible only to authorised compliance personnel, auditors, and regulatory authorities conducting lawful inspections or investigations.

6. Customer Obligations

Customers using Flamingo Casino facilities are required to:

Provide accurate, current, and complete identification and personal information when requested.
Notify the casino promptly of any change in personal details, residential address, or other material information.
Cooperate with verification procedures and respond to requests for additional documentation within the specified timeframes.
Refrain from structuring transactions to evade reporting thresholds or providing false, misleading, or incomplete information.

Failure to comply with these obligations may result in refusal of service, suspension of account facilities, closure of accounts, and reporting of the conduct to the relevant authorities. In cases where criminal activity is suspected, the matter may be referred to law enforcement agencies.

7. Data Protection and Confidentiality

Personal information collected for AML and KYC purposes is processed in accordance with the Protection of Personal Information Act (POPIA) and applicable internal data protection policies. Customer data is used solely for compliance with legal obligations, risk management, and the prevention and detection of financial crime.

Customer information is not shared with third parties except:

When required to do so by law, court order, or regulatory directive.
When disclosed to group compliance functions, auditors, or legal advisors who are subject to confidentiality obligations.
When reported to the Financial Intelligence Centre or other competent authorities as part of a suspicious transaction report or in response to a lawful request.

Appropriate technical and organisational measures are applied to protect customer data against unauthorised access, loss, or misuse, in line with applicable legal and regulatory requirements.

8. Refusal of Service and Account Closure

Flamingo Casino reserves the right to refuse service, decline a transaction, or close a customer account without prior notice if:

The customer fails to provide satisfactory identification or verification documents.
Due diligence measures cannot be completed to the satisfaction of the casino or of the relevant regulators.
The customer’s activity is assessed as presenting an unacceptable money laundering, terrorist financing, or compliance risk.
Compliance with a law, court order, directive from the Financial Intelligence Centre, or instruction from the gambling regulator requires such action.

In these circumstances, any funds held on account, excluding winnings or funds reasonably suspected to be derived from suspicious activity, will be returned to the customer by a method determined by the compliance function, subject to completion of any outstanding verification or investigation.

9. Staff Training and Internal Controls

All staff members with customer-facing, transactional, or relevant operational responsibilities receive training on:

AML and KYC obligations under FICA and related regulations.
Identification of suspicious transactions and behaviours.
Internal procedures for escalation, reporting, and record keeping.

The compliance framework at Flamingo Casino includes:

Appointment of a designated Money Laundering Reporting Officer responsible for oversight of AML controls and liaison with the FIC.
Internal audit, monitoring, and testing of AML procedures at intervals determined by the internal risk assessment.
Documented policies and procedures accessible to relevant staff.
Disciplinary measures and corrective action in cases of non-compliance with AML and KYC requirements.

10. Updates and Amendments

This AML / KYC policy is reviewed periodically to reflect changes in legislation, regulatory guidance, and internal risk assessments. The policy may be amended at any time without prior notice.

The current version of the policy is available on request at the customer service desk and may be provided to customers as part of account opening procedures or high-value transaction processes. Customers are responsible for familiarising themselves with the current policy and for complying with any new or amended requirements communicated by staff.

11. Contact and Queries

Questions regarding this AML / KYC policy, customer verification procedures, or the status of a transaction may be directed to the compliance team via the customer service desk at Flamingo Casino. Responses will be provided in accordance with internal procedures and applicable legal obligations. Certain information, including the existence or content of any suspicious transaction report, cannot be disclosed.

For regulatory or legal enquiries, customers may contact the Northern Cape Gambling Board or the Financial Intelligence Centre directly, using the contact details published by those bodies.