Khoroni Casino AML / KYC Policy

1. Introduction and Purpose

This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applicable to Khoroni Casino, a land-based casino and resort property located in Thohoyandou, Limpopo Province, South Africa.

The purpose of this policy is to define the obligations of Khoroni Casino and its customers in relation to the prevention of money laundering, terrorist financing, and other forms of financial crime. The policy applies to all transactions, customer relationships, and activities conducted on the premises of Khoroni Casino.

Khoroni Casino operates in accordance with applicable South African legislation, regulatory guidance, and international standards governing anti-money laundering and counter-terrorist financing (AML/CTF).

2. Legal Framework

Khoroni Casino operates as an accountable institution under South African law. The primary legislative framework governing AML and KYC obligations at Khoroni Casino includes the following:

• Financial Intelligence Centre Act (FICA), which is the principal AML/CTF statute in South Africa, establishes the Financial Intelligence Centre (FIC), and imposes customer due diligence, record-keeping, and reporting obligations on accountable institutions, including casinos.
• Classification of casinos in South Africa as designated non-financial businesses and professions (DNFBPs) under FICA, which subjects them to the full range of AML/CTF obligations prescribed by that Act and its associated regulations.
• Licensing conditions imposed by the relevant provincial gambling authority in Limpopo Province, which include requirements consistent with FICA and aligned with Financial Action Task Force (FATF) standards.

3. Scope of Application

This policy applies to:

• All customers engaging in cash or non-cash transactions at Khoroni Casino that meet or exceed prescribed thresholds.
• All customers applying for or holding loyalty programme memberships, credit accounts, or player accounts.
• All transactions involving the purchase or redemption of chips, tokens, or gaming credits.
• All electronic funds transfers and cheque-cashing activities conducted through the casino.
• All customer relationships that present indicators of elevated risk.

4. Know Your Customer (KYC) Procedures

4.1 Customer Identification and Verification

Khoroni Casino is required to identify and verify the identity of customers before or during the establishment of a business relationship, and when conducting transactions that trigger KYC obligations under FICA or internal risk thresholds.

The following information is collected from customers subject to KYC requirements:

• Full legal name
• Date of birth
• Residential address
• Nationality
• Government-issued identification document details

Acceptable forms of identification include a valid South African identity document, a valid passport, or another government-issued document that includes a photograph and sufficient personal details to confirm identity.

Khoroni Casino verifies the information provided by customers using reliable and independent sources, which may include physical inspection of original documents, cross-referencing with official databases, or other verification methods consistent with regulatory guidance.

4.2 Customer Due Diligence

Khoroni Casino applies a risk-based approach to customer due diligence (CDD). The level of due diligence applied to a customer relationship is proportionate to the assessed risk associated with that customer and their transactions.

Standard due diligence is applied to customers presenting a standard risk profile.

Enhanced due diligence (EDD) is applied to customers who present a higher risk of money laundering or terrorist financing. Categories of customers subject to EDD include, but are not limited to:

• Politically exposed persons (PEPs) and their associates
• Customers from jurisdictions identified as high-risk by FATF or the FIC
• Customers whose source of funds or source of wealth cannot be readily established
• Customers whose transaction patterns are inconsistent with their stated profile

EDD may require the collection of additional documentation, verification of source of funds or source of wealth, closer ongoing monitoring, and approval by senior management before a business relationship is established or continued.

4.3 Ongoing Monitoring

Khoroni Casino conducts ongoing monitoring of customer activity throughout the duration of a business relationship. This includes reviewing transactions to assess whether they are consistent with the casino’s knowledge of the customer, their risk profile, and their stated source of funds.

Where customer activity changes materially, or where new information comes to light that affects the risk assessment of a customer, Khoroni Casino updates its customer records and, where necessary, conducts additional due diligence.

5. Transaction Monitoring and Reporting

5.1 Transaction Monitoring

Khoroni Casino monitors transactions for indicators of suspicious or unusual activity. Indicators that may trigger internal review include, but are not limited to:

• Large cash buy-ins or cash-outs that are inconsistent with normal gaming activity
• Structuring of transactions to avoid reporting thresholds
• Purchase of chips followed by minimal play and early cash-out
• Use of third-party intermediaries to conduct transactions
• Transactions involving funds from unidentified or unexplained sources

5.2 Reporting Obligations

Khoroni Casino is required under FICA to report the following to the Financial Intelligence Centre:

• Cash threshold reports (CTRs) for cash transactions that meet or exceed the prescribed monetary threshold under applicable regulations.
• Suspicious and unusual transaction reports (STRs/UTRs) 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.

Reports are submitted to the FIC in accordance with the timelines and formats prescribed by applicable legislation and FIC guidance notes.

6. Record-Keeping

Khoroni Casino maintains records of customer identification information and transaction data for the periods prescribed under FICA and associated regulations. Records are retained in a manner that allows them to be retrieved and provided to the FIC or other competent authorities upon lawful request.

7. Compliance Responsibilities

Khoroni Casino has designated a compliance officer responsible for overseeing the implementation of this AML/KYC policy, ensuring that internal controls are maintained, and acting as the primary point of contact for regulatory matters related to AML/CTF compliance.

All staff members who interact with customers or handle transactions receive training on AML/CTF obligations, including the identification of red-flag indicators and the internal procedures for escalating suspicious activity.

Khoroni Casino conducts periodic internal reviews and independent audits of its AML/KYC programme to assess its effectiveness and ensure continued alignment with legislative requirements and regulatory expectations.

8. Customer Obligations

Customers of Khoroni Casino are required to:

• Provide accurate and complete identification information when requested
• Present valid, original identification documents upon request
• Provide information regarding source of funds or source of wealth when required under enhanced due diligence procedures
• Cooperate with any additional verification steps initiated by Khoroni Casino in fulfilment of regulatory obligations

Failure to provide required documentation or information may result in Khoroni Casino being unable to complete a transaction, establish a business relationship, or continue an existing relationship.

9. Policy Review

This policy is reviewed periodically to ensure consistency with amendments to FICA, FIC guidance notes, provincial gambling authority requirements, and FATF standards. Updates to this policy take effect upon publication and apply to all existing and new customer relationships.