Umfolozi Casino AML / KYC Policy
- Introduction and Scope
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applicable to Umfolozi Hotel Casino Convention Resort, hereinafter referred to as Umfolozi Casino, located at 2 Copper Drive, Kuleka, Empangeni, KwaZulu-Natal, South Africa. Umfolozi Casino forms part of the Peermont group and operates as a licensed land-based casino within the KwaZulu-Natal province.
This policy applies to all persons who access gaming services, conduct financial transactions, or otherwise engage with Umfolozi Casino in any capacity that triggers compliance obligations under applicable South African law. The policy sets out the obligations of both Umfolozi Casino and its customers with respect to identity verification, transaction monitoring, record-keeping, and reporting.
Umfolozi Casino is classified as an accountable institution under the Financial Intelligence Centre Act, 2001 (FICA), as amended. All AML and KYC procedures described in this document are implemented in accordance with FICA, the Prevention of Organised Crime Act (POCA), the Protection of Constitutional Democracy against Terrorist and Related Activities Act (POCDATARA), and the conditions of the casino licence issued by the KwaZulu-Natal Gambling and Racing Board.
2. Legal and Regulatory Framework
2.1 Applicable Legislation
The following legislative instruments govern the AML and KYC obligations of Umfolozi Casino:
- Financial Intelligence Centre Act, 2001 (FICA) and its amendments - establishes the obligations of accountable institutions to perform customer due diligence, maintain records, and report certain transactions to the Financial Intelligence Centre (FIC).
- Prevention of Organised Crime Act, 1998 (POCA) - criminalises money laundering and the acquisition, possession, or use of proceeds of unlawful activities.
- Protection of Constitutional Democracy against Terrorist and Related Activities Act, 2004 (POCDATARA) - addresses counter-terrorist financing obligations.
- KwaZulu-Natal Gambling Act and provincial licence conditions - impose additional compliance requirements specific to casino operations within the province.
2.2 Regulatory Oversight
Umfolozi Casino is subject to oversight by the Financial Intelligence Centre (FIC) for AML and counter-terrorist financing (CTF) compliance, and by the KwaZulu-Natal Gambling and Racing Board for provincial casino licence conditions. Umfolozi Casino operates within the group compliance framework of the Peermont group, which sets minimum standards applicable across all Peermont-operated properties.
3. Customer Due Diligence (KYC)
3.1 Obligation to Verify Identity
Umfolozi Casino is required to establish and verify the identity of customers before or during the establishment of a business relationship, and in connection with single transactions that meet or exceed prescribed thresholds under FICA. No customer may receive gaming services or conduct regulated transactions without satisfying applicable identity verification requirements.
3.2 Minimum Age Requirement
All persons seeking access to gaming areas or gaming services must be 18 years of age or older. Age verification is a mandatory component of the KYC process. Umfolozi Casino reserves the right to request proof of age from any person at any time. Persons who cannot demonstrate that they meet the minimum age requirement will be refused access to gaming facilities.
3.3 Identity Documents Required
Customers subject to KYC verification are required to present valid, government-issued identity documentation. Acceptable documents include, but are not limited to:
- South African green barcoded identity document or smart identity card issued by the Department of Home Affairs.
- Valid South African passport.
- Valid foreign passport for non-South African nationals.
Where applicable, additional documentation may be requested to verify residential address, source of funds, or other information required to complete customer due diligence in accordance with FICA.
3.4 Enhanced Due Diligence
Enhanced due diligence (EDD) applies in circumstances where a customer presents a higher risk profile. This includes, but is not limited to:
- customers identified as Politically Exposed Persons (PEPs)
- customers conducting transactions of significant value
- customers whose transaction patterns are inconsistent with their stated profile
- customers in respect of whom there are reasonable grounds to suspect money laundering or terrorist financing activity.
In such cases, Umfolozi Casino may require additional documentation, conduct further verification steps, or escalate the matter to the designated Money Laundering Reporting Officer (MLRO) before proceeding with any transaction or service.
3.5 Ongoing Monitoring
Customer due diligence is not limited to the point of initial verification. Umfolozi Casino conducts ongoing monitoring of transactions and customer behaviour throughout the business relationship. Where changes in a customer’s circumstances or transaction patterns indicate an elevated risk, Umfolozi Casino may initiate a review and request updated documentation or information.
4. Transaction Monitoring and Reporting
4.1 Cash Transaction Reporting
In accordance with FICA, Umfolozi Casino is required to report cash transactions above prescribed thresholds to the Financial Intelligence Centre. Customers conducting cash transactions at or above these thresholds are required to provide identity documentation and, where applicable, information regarding the source of funds. Refusal to provide required information may result in the transaction being declined.
4.2 Suspicious Transaction Reporting
Umfolozi Casino is obligated to file Suspicious Transaction Reports (STRs) with the Financial Intelligence Centre where there are reasonable grounds to suspect that a transaction involves the proceeds of unlawful activity or is connected to money laundering or terrorist financing. The obligation to report is not contingent on the value of the transaction. Customers are advised that Umfolozi Casino is legally prohibited from disclosing to any person that a report has been or may be filed.
4.3 Terrorist Property Reporting
Where Umfolozi Casino has knowledge or reasonable grounds to suspect that property in its possession or control is connected to terrorist activity or terrorist financing, it is required to report this to the relevant authorities in accordance with POCDATARA and FICA.
5. Record-Keeping
Umfolozi Casino maintains records of all customer identification documentation, transaction records, and due diligence information for the minimum retention periods prescribed by FICA. Records are stored securely and are made available to the Financial Intelligence Centre or other competent authorities upon lawful request. Customers do not have the right to request deletion of records that are required to be retained under applicable law.
6. Customer Obligations
Customers engaging with Umfolozi Casino are required to:
- provide accurate, complete, and truthful information when requested for identity verification or due diligence purposes
- present valid, unexpired identity documentation upon request
- cooperate with any additional verification steps required under enhanced due diligence procedures
- refrain from any conduct intended to circumvent AML or KYC controls, including structuring transactions to avoid reporting thresholds.
Failure to comply with these obligations may result in refusal of service, termination of the business relationship, and, where applicable, reporting to the relevant authorities.
7. Non-Compliance and Consequences
Umfolozi Casino reserves the right to refuse, suspend, or terminate any transaction or service where a customer fails to satisfy KYC requirements or where there are grounds to suspect non-compliance with applicable AML obligations. Such refusal does not give rise to any liability on the part of Umfolozi Casino.
Where required by law, Umfolozi Casino will report non-compliant conduct or suspicious activity to the Financial Intelligence Centre, the KwaZulu-Natal Gambling and Racing Board, or other competent authorities.
8. Responsible Gambling and Related Obligations
Umfolozi Casino supports the National Responsible Gambling Programme (NRGP). Customers experiencing gambling-related difficulties may contact the Problem Gambling Counselling toll-free helpline at 0800 006 008. The minimum age for participation in any gaming activity at Umfolozi Casino is 18 years. These requirements operate alongside and independently of the AML and KYC obligations set out in this policy.
9. Contact Information
For queries relating to this policy or to AML and KYC procedures at Umfolozi Casino, customers may use the following contact details:
- Address: 2 Copper Drive, Kuleka, Empangeni, KwaZulu-Natal, South Africa, 3880
- Postal Address: Private Bag X20030, Empangeni, 3880, KwaZulu-Natal
- Telephone: +27 (0) 35 787 8200
- Email: [email protected]
- Website: umfolozicasino.co.za