Mykonos Casino AML / KYC Policy

1. Introduction and Purpose

Mykonos Casino operates as a regulated gambling venue in South Africa and is subject to national and provincial legal obligations governing anti-money laundering (AML) and know your customer (KYC) compliance. This document sets out the framework under which Mykonos Casino identifies customers, monitors transactions, and fulfils obligations under applicable South African law.

The primary legislative basis for these obligations is the Financial Intelligence Centre Act (FICA) and its associated regulations, which classify casinos as accountable institutions required to implement AML and KYC controls. Mykonos Casino is required to comply with these requirements and to cooperate with relevant regulatory and law enforcement authorities.

2. Regulatory Framework

Mykonos Casino operates within South Africa’s formal gambling sector and holds the applicable provincial licence issued by the relevant gambling authority in the Western Cape. As an accountable institution under FICA, Mykonos Casino is required to:

• Establish and maintain a documented AML compliance programme
• Appoint a designated compliance officer responsible for AML and KYC oversight
• Conduct customer due diligence at prescribed thresholds and risk levels
• Monitor customer transactions for suspicious or unusual activity
• Report suspicious transactions to the Financial Intelligence Centre (FIC)
• Maintain records of customer identification and transaction data for the legally required retention period

Non-compliance with these obligations may result in regulatory sanctions, including administrative penalties and criminal prosecution under South African law.

3. Customer Identification and Verification

3.1 Identity Verification Requirements

Mykonos Casino is required to verify the identity of customers before or at the point of establishing a business relationship, or before conducting a transaction that meets or exceeds applicable thresholds. Customers are required to present valid, government-issued photographic identification. Acceptable documents include a South African identity document, a valid passport, or another form of identification recognised under applicable regulations.

The following personal information is collected and verified:

• Full legal name
• Date of birth
• Residential address
• Identity or passport number
• Nationality

3.2 Verification Process

Verification is conducted at the time of account registration or at the point of a qualifying transaction. Mykonos Casino may request additional documentation where initial verification is insufficient or where the customer’s risk profile requires further review. Customers who do not provide the required documentation are not permitted to conduct transactions until verification is completed.

4. Customer Due Diligence

4.1 Standard Due Diligence

Standard customer due diligence (CDD) applies to all customers and involves the collection and verification of identity information as described in section 3. CDD is conducted at the commencement of a customer relationship and is subject to ongoing review.

4.2 Enhanced Due Diligence

Enhanced due diligence (EDD) is applied to customers who present a higher risk profile. This includes, but is not limited to:

• Customers identified as politically exposed persons (PEPs) or their associates
• Customers conducting high-value transactions above defined internal thresholds
• Customers whose transaction patterns are inconsistent with their stated profile
• Customers identified through adverse media screening or sanctions list checks

EDD may require the customer to provide documentation confirming the source of funds (SOF) and source of wealth (SOW). Mykonos Casino may restrict or suspend a customer’s access pending the outcome of an EDD review.

5. Transaction Monitoring

Mykonos Casino maintains ongoing monitoring of customer transactions to detect patterns that may indicate money laundering, fraud, or other financial crime. Monitoring procedures are designed to identify, among other indicators:

• Structuring of transactions to avoid reporting thresholds (commonly referred to as smurfing)
• Unusual patterns of chip purchase, redemption, or cash exchange
• Transactions inconsistent with a customer’s known profile or stated purpose
• Repeated high-value cash transactions without a clear legitimate explanation

Where a transaction or pattern of behaviour raises a reasonable suspicion of financial crime, Mykonos Casino is obligated to file a Suspicious Transaction Report (STR) with the Financial Intelligence Centre in accordance with FICA requirements. Customers are not notified when an STR is filed, as disclosure is prohibited by law.

6. Recordkeeping

Mykonos Casino retains records of customer identification documents, due diligence findings, transaction logs, and AML reporting for at least the minimum period prescribed by applicable law. These records are maintained securely and are made available to regulatory authorities upon lawful request.

7. Customer Obligations

Customers of Mykonos Casino are required to:

• Provide accurate and complete identification information upon request
• Submit supporting documentation when requested as part of CDD or EDD procedures
• Notify Mykonos Casino of any material changes to their personal information
• Cooperate with verification and monitoring procedures as a condition of access

Provision of false, misleading, or incomplete information constitutes a breach of these requirements and may result in suspension of access, reporting to relevant authorities, and potential legal consequences under South African law.

8. Data Protection

Personal data collected for AML and KYC purposes is processed in accordance with applicable South African data protection legislation. Such data is used solely for compliance, regulatory, and legal purposes and is not shared with third parties except where required by law or by a competent regulatory authority. Customers have rights in relation to their personal data as provided under applicable legislation, subject to limitations where disclosure would conflict with legal obligations such as tipping-off restrictions under FICA.

9. Compliance Programme

Mykonos Casino maintains a written AML compliance programme that includes documented policies and procedures, a designated compliance officer, regular staff training on AML and KYC obligations, and periodic independent review and audit of compliance controls. The programme is reviewed and updated in response to changes in applicable law, regulatory guidance, and identified compliance risks.

10. Contact and Reporting

Customers with questions regarding this policy or their verification status may contact Mykonos Casino through the official channels available at the venue or through the contact details published in the casino’s official documentation. Mykonos Casino does not accept anonymous enquiries in relation to AML or KYC matters.

This policy is effective as of its date of publication and supersedes any prior version. Mykonos Casino reserves the right to amend this policy at any time in response to changes in applicable law or regulatory requirements.