Casino Christchurch AML and KYC Policy

1. Overview and Regulatory Basis

Casino Christchurch, operated by Christchurch Casinos Limited, is a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act) of New Zealand. As a licensed casino operator, the company is subject to AML/CFT supervision by the Department of Internal Affairs (DIA), which is the designated supervisory authority for casinos under New Zealand law.

This document sets out the obligations that Casino Christchurch is required to fulfil under the AML/CFT Act, the procedures applied to customers in connection with those obligations, and the rights and responsibilities of both the casino and its customers in the context of AML and KYC compliance.

All persons who conduct transactions or maintain accounts at Casino Christchurch are subject to the procedures described in this policy. Compliance with these procedures is a legal requirement and a condition of continued access to casino services.

2. Purpose of AML and KYC Controls

The AML/CFT Act requires Casino Christchurch to detect, manage, and mitigate the risk of money laundering and the financing of terrorism. To fulfil this obligation, the company is required to:

• Establish, implement, and maintain an AML/CFT compliance programme.
• Conduct customer due diligence (CDD) and, where required, enhanced customer due diligence (EDD).
• Monitor customer accounts and transaction activity on an ongoing basis.
• Keep records as required by the AML/CFT Act.
• Terminate business relationships where required by law or internal risk assessment.
• Report suspicious activities and transactions to the relevant authorities in accordance with the Act.

These obligations exist to uphold the integrity of New Zealand’s financial system and to ensure that Casino Christchurch does not become a vehicle for financial crime.

3. Customer Identification and Verification (KYC)

3.1 When Identification Is Required

Casino Christchurch is required to verify the identity of customers in the following circumstances:

• When a customer conducts a cash transaction of NZD 6,000 or more, whether as a single transaction or as linked transactions.
• When a customer opens a casino deposit account or a QUICK Pay account.
• When the casino’s risk assessment determines that identification or re-verification is necessary.
• When a business relationship is established or continued with a customer who presents elevated risk indicators.

3.2 Acceptable Identity Documents

Customers may be required to present one or more of the following documents to satisfy identity verification requirements:

• Government-issued photo ID (passport, driver licence) - primary identity verification.
• Proof of residential address (utility bill, bank statement) - address verification.
• Bank statements or financial records - source of funds verification.
• Business records or receipts - source of funds or source of wealth verification.

The specific documents requested will depend on the nature of the transaction, the customer’s risk profile, and the applicable due diligence tier.

3.3 Source of Funds and Source of Wealth

In certain circumstances, Casino Christchurch is required to verify the source of funds used in transactions and, in limited cases, the source of a customer’s overall wealth. This requirement applies where a customer’s activity or profile indicates elevated risk under the AML/CFT compliance programme. Customers may be asked to provide documentary evidence such as bank statements, payslips, business records, or other financial documentation.

Failure to provide requested documentation may result in the refusal or suspension of transactions and, where required by law, the termination of the business relationship.

4. Enhanced Customer Due Diligence (EDD)

Enhanced customer due diligence applies where standard CDD measures are insufficient to manage the identified risk. EDD may be triggered by:

• High-value transactions or patterns of transactions that exceed standard risk thresholds.
• Customer profiles that indicate elevated exposure to money laundering or terrorism financing risk.
• Transactions involving sources of funds that cannot be readily verified.
• Circumstances identified through ongoing account monitoring.

Where EDD is required, Casino Christchurch will request additional information and documentation from the customer before proceeding with the relevant transaction or continuing the business relationship.

5. Ongoing Monitoring

Casino Christchurch conducts ongoing monitoring of customer accounts and transaction activity. This monitoring is designed to identify transactions or patterns of behaviour that are inconsistent with a customer’s known profile or that may indicate money laundering or terrorism financing risk. Monitoring is conducted in accordance with the AML/CFT compliance programme and the requirements of the AML/CFT Act.

Where monitoring identifies activity that requires further review, Casino Christchurch may request additional information from the customer, place restrictions on account activity, or take other steps as required by law.

6. Record-Keeping

Casino Christchurch maintains records of customer identification information, transaction data, and due diligence documentation in accordance with the requirements of the AML/CFT Act. Records are retained for the periods prescribed by law and are made available to the DIA or other authorised authorities upon lawful request.

7. Compliance History and Remediation

Casino Christchurch acknowledges that the DIA filed civil proceedings in the High Court of New Zealand in December 2024 alleging multiple breaches of the AML/CFT Act by Christchurch Casinos Limited during the period December 2018 to December 2023. The alleged breaches included failures to maintain an AML/CFT compliance programme, conduct adequate enhanced customer due diligence, terminate business relationships when required, monitor accounts appropriately, and keep records as required by the Act.

Following those proceedings, the New Zealand High Court imposed a civil penalty of NZD 5.06 million, representing the largest AML/CFT penalty imposed on a New Zealand reporting entity at that time. The penalty related in part to failures to identify red flags associated with approximately NZD 56 million in transactions.

Casino Christchurch, through its CEO Brett Anderson, has publicly accepted responsibility for its AML failings and has apologised to stakeholders and the wider community. Casino Christchurch is required to meet its obligations under the AML/CFT Act and to maintain a compliance programme that satisfies the requirements of the DIA and the Act.

8. Customer Obligations

Customers of Casino Christchurch are required to:

• Provide accurate and complete information when requested for identity verification or due diligence purposes.
• Provide documentary evidence of identity, address, source of funds, or source of wealth when requested.
• Cooperate with any requests made by Casino Christchurch in connection with its AML/CFT obligations.
• Notify Casino Christchurch of any material changes to information previously provided.

Providing false, misleading, or incomplete information in response to AML/KYC requests may constitute a breach of New Zealand law and may result in the refusal of services and referral to relevant authorities.

9. Regulatory Authority

The supervisory authority responsible for AML/CFT compliance oversight of Casino Christchurch is:

Department of Internal Affairs (DIA)
New Zealand

The DIA has authority to conduct audits, request information, and take enforcement action against reporting entities that fail to comply with the AML/CFT Act.

10. Updates to This Policy

This policy reflects Casino Christchurch’s obligations under the AML/CFT Act as currently in force. The policy may be updated from time to time to reflect changes in legislation, regulatory guidance, or the internal compliance programme. Customers are advised to review this document periodically.