November2023
1. INTRODUCTION
Castle Hill RSL Club Ltd (CHRG) is committed to complying with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and taking a proactive approach to prevent money laundering across our venues. To the extent permissible by law, CHRG will satisfy its obligations in a manner which is consistent with business efficiency, the requirements of other relevant laws and the best interests of CHRG’s customers who do not pose any material ML/TF risk.
The purpose of this policy is to outline the framework that CHRG has in place to ensure best practice in AML/CTF compliance. This policy applies to all team members of CHRG and is overseen by the CHRG gaming department.
2. OUR APPROACH TO AML/CTF
To ensure a proactive approach to AML/CTF CHRG has undertaken an AML/CTF risk assessment and has a adopted the industry standardAML/CTFprogramasprovidedby ClubsNSW/ClubSafe. The program wasapproved by the Board of Directors and a Compliance Officer was designated. The Compliance Officer for the Group is the Group Gaming, Loyalty, and Compliance Manager.
The program includes the following components:
Employee Due Diligence Checks
Transaction Monitoring
Suspicious Behaviour Reporting
Know Your Customer (KYC)
Customer Due Diligence (CDD) and Enhanced Customer Due Diligence (ECDD)
Politicly Exposed Person Due Diligence (PEP)
Record Keeping
More on details on our approach are provided in CHRG’s AML/CTF Program Part A and B and accompanying procedures.
3. BREACH OF THIS POLICY
Breachesof thispolicy and accompanying programs and procedures may resultin counselling and or disciplinary action, up to and including dismissal.
4. REVIEW OF THIS POLICY
This policy will be reviewed every two years to ensure it remains consistent with all relevant legislative requirements, as well as the changing nature of the company or more frequently where legislative requirements are changed or amended.
5. POLICY COMMUNICATION AND EDUCATION
This policy will be stored on CHRG’s intranet site. It will be incorporated into induction/onboarding programs and CHRG will conduct education sessions on the application and operation of this policy as required and when any changes to the policy are implemented.
6. DOCUMENT HISTORY
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