connect_policy_AML & CTF Procedure

November2023

1. INTRODUCTION

The purpose of this procedure is to outline the internal AML/CTF processes that CHRG follows to ensure best practice in AML/CTF compliance.

This Procedure is underpinned by CHRG’s AML/CTF Policy and AML/CTF Program Part A and B.

1.1.Definitions

 AML/CTF – Anti Money Laundering / Counter Terrorism Financing

 ML/TF – Money Laundering / Terrorism Financing

 SMR – Suspicious Matter Report

 KYC – Know Your Customer

 CDD – Customer Due Diligence

 ECDD – Enhanced Customer Due Diligence

 PEP – Politicly Exposed Person

2. EMPLOYEE DUE DILIGENCE CHECKS

Upon commencement the People team will carry out the follow due diligence checks on all new team members and/or existing team members moving into gaming roles.

 Non-Gaming Staff

- Reference checks

- Verify work history

- Pre-employment screening questionnaires

 Gaming Staff

- RCG training

- Criminal history checks

 Leaders

- Advanced RCG Training

3. EMPLOYEE TRAINING & EDUCATION

CHRG will ensure all gaming team members are aware of CHRG’s and their obligations and responsibilities regarding AML/CT by providing regular training and education. This includes:

 CHRG Induction – CHRG – Face-to-face – Annual

 AML/CTF Staff Awareness – Clubs NSW – Online – Annual

 Liquor and Gaming Compliance Fundamentals – ClubsNSW – Online – Annual

 NSW Responsible Gaming Staff Awareness – ClubsNSW – Online – Annual

 Gaming Service Training – CHRG – Face-to-Face – Bi-annual

 Monthly educational topics (Senior Leadership Meetings)

After being notified of any team members commencing in a gaming area, team members are enrolled into the ClubsNSW training portal by the People team. The People team will ensure:

 Team members complete training in the desired time frame.

 Re-enrol team members to complete training every twelve months.

The Group Gaming, Loyalty and Compliance Manager is responsible for Gaming Service Training.

A copy of the Policy, Program and Procedure will be available on the Connect+ Hub.

4. TRANSACTION MONITORING

Transactional monitoring will include the following daily and monthly activities:

Daily

 All CHQ/EFT payments will be added to a register, recording payment details and KYC information on each recipient.

 A Suspicious Gaming Activity Report will be run from the Central Monitoring System and details will be recorded on the register.

 Any entries that are over $1000 collected with less than 5 games played will be investigated utilising the Internal Investigation Report template.

 All completed reports will be retained in the secure file and sent to the Compliance Officer for review and a determination will be made if a transaction requires a SMR.

 Where deemed suspicious a SMR will be completed.

 The Compliance Officer will determine to either to continue relationship with patron, or to discontinue the relationship following CHRG’s process of patron disciplinary action.

 ECDD is to be taken for customers with reoccurring appearance in the Suspicious Report through the filing of an internal Regular Patron Gameplay Report.

Monthly

 A review CHQ/EFT Register will be completed, with the following to be identified:

- The top three payments by $ value of each venue

- The top number of payments to the same patron for each venue.

 A ECDD will be undertaken, and investigation completed by undertaking a meter reconciliation of winning machine utilising the Internal Investigation Report template.

 Where deemed suspicious a SMR will be completed, and the process outlined above will be followed.

5. SUSPICIOUS BEHAVIOUR REPORTING

 Team members will report suspicious gaming behaviour to the Customer Service Manager who will email the details to the Compliance Officer.

 An investigation will be completed utilising the Internal Investigation Report template and the process outlined above will be followed.

6. KNOW YOUR CUSTOMER (KYC)

 The following members information is maintained in the membership system: - Name - Address - Date of birth.

- Email / phone number

- Government ID sighted by staff to verify.

 The following visitors’ information is recorded via sign-in:

- Name - Address - Date of birth.

- Government ID sighted by staff to verify.

7. CUSTOMER DUE DILIGENCE (CDD)

 All payments by cheque will be accompanied by a Customer Due Diligence Form that records:

- Players full name, residential address, date of birth, phone number.

- Manger sights Government issued ID and signs form to verify.

- Copy of Members card / visitors slip.

- Copy of payout voucher.

- All information recorded on Cheque register spreadsheet.

 All gaming related investigations will be completed using the process outlined in this policy and will be recorded and actioned accordingly.

8. ENHANCED CUSTOMER DUE DILIGENCE (ECDD)

Where activity is deemed high risk, or a SMR is completed and at the time of monthly upgrades to Diamond and Double Diamond Member rewards tier the following process will be followed:

 Fill out ECDD spreadsheet.

 Google search, save PDF copy in folder.

 Green ID check.

9. POLITICLY EXPOSED PERSON DUE DILIGENCE (PEP)

The following process will be conducted monthly to identify PEP:

 A report will be generated for all new members that have played a gaming machine in the month.

 Undertake an ECDD on top 5 patrons

- When undertaking ECDD, look for signs they may be a PEP.

- If identified as PEP an Internal Investigation Report will be completed and reviewed by the Compliance Officer and the process outlined in this policy will be completed.

10. RECORD KEEPING

 Policy, Program and Procedures

- Connect+ Hub

 Transaction records

- Ebet Gaming system

- Secure File share

 Customer identification records

- eBet Gaming system for membership

- Circle Scan for visitor register

- Secure File share

 AML/CTF Program Management

- Secure File share

 Employee records

- Electronic personnel file and training registers

 Board report

- Templated report tabled at each monthly Board meeting.

- Secure File share

11. DOCUMENT HISTORY