Skycity Casino Hamilton AML / KYC Policy

1. Overview and Legal Basis

Skycity Casino Hamilton operates as a land-based casino in Hamilton, New Zealand, under licences held by SkyCity Casino Management Limited (SCML), a subsidiary of SkyCity Entertainment Group Limited. As a licensed casino operator in New Zealand, SCML is classified as a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act). This legislation establishes the primary legal framework governing all anti-money laundering and know your customer (KYC) obligations applicable to Skycity Casino Hamilton.

The Department of Internal Affairs (DIA), Te Tari Taiwhenua, is the designated AML/CFT supervisor for casinos in New Zealand, including Skycity Casino Hamilton. All AML/CFT obligations described in this document arise from the AML/CFT Act 2009 and associated regulations administered by the DIA.

Skycity Casino Hamilton operates in accordance with an AML/CFT programme that has been in place since the commencement of the AML/CFT Act. This programme applies across all casino venues operated by SCML, including the Hamilton property.

2. Purpose of This Policy

This document describes the AML/CFT and KYC obligations that apply to customers of Skycity Casino Hamilton. It sets out the circumstances under which identity verification is required, the types of documentation accepted, the categories of due diligence that may be applied, and the obligations of both the casino and the customer in relation to AML/CFT compliance.

This document does not constitute legal advice. Customers with questions regarding their specific obligations under New Zealand law should seek independent legal guidance.

3. Customer Due Diligence (CDD) Requirements

3.1 When Identity Verification Is Required

Skycity Casino Hamilton is required by law to verify the identity of customers in the following circumstances:

• When a customer conducts a single cash transaction of NZ$6,000 or more, or a series of linked transactions that together reach or exceed NZ$6,000.
• When a customer opens a casino deposit account or a QUICK Pay account at any SkyCity casino, including Skycity Casino Hamilton.
• When a customer is assessed as presenting a higher level of risk under the casino’s internal risk assessment framework.
• When the casino determines that additional identification is required under the AML/CFT Act 2009 in connection with any transaction or business relationship.

Customers may be asked to provide identification at any point during their visit if it is determined that AML/CFT obligations require it.

3.2 Acceptable Identity Documents

For standard customer due diligence, Skycity Casino Hamilton accepts the following forms of identification:

• Current passport - must be valid and government-issued.
• New Zealand driver licence - must be current and valid.

3.3 Additional Documentation for Account Opening

Customers opening a casino deposit account or QUICK Pay account are required to provide, in addition to primary identity documentation, proof of home address. Acceptable proof of address includes documents such as a current utility bill issued in the customer’s name. The casino reserves the right to request additional documentation where required to satisfy AML/CFT obligations.

4. Enhanced Customer Due Diligence (Enhanced CDD)

In certain circumstances, Skycity Casino Hamilton is required to conduct enhanced customer due diligence. Enhanced CDD applies where a customer or transaction is assessed as presenting a higher risk of money laundering or terrorism financing. This may include, but is not limited to, customers classified as international business customers or customers conducting large electronic transfers.

Under enhanced CDD, the casino may require:

• Verification of the source of funds involved in a transaction.
• Verification of the source of a customer’s wealth, where applicable.
• Additional documentation or information beyond that required for standard CDD.

Customers subject to enhanced CDD are required to cooperate with these requests. Failure to provide required information may result in the casino declining to proceed with a transaction or terminating the business relationship in accordance with obligations under the AML/CFT Act.

5. Ongoing Monitoring and Transaction Reporting

Skycity Casino Hamilton maintains ongoing monitoring of customer accounts and transactions as required under the AML/CFT Act. This includes monitoring for unusual or suspicious activity and compliance with reporting obligations to relevant authorities where required by law.

The casino is required to file suspicious transaction reports (STRs) and prescribed transaction reports (PTRs) with the New Zealand Police Financial Intelligence Unit where applicable thresholds or triggers are met. These reporting obligations are mandatory and are not subject to customer consent.

6. Termination of Business Relationships

Where Skycity Casino Hamilton determines that it is unable to conduct required customer due diligence, or where a customer fails to provide information necessary to satisfy AML/CFT obligations, the casino is required to terminate or decline to enter into the relevant business relationship. This obligation arises from the AML/CFT Act and is not discretionary.

7. Mandatory Carded Play

Skycity Casino Hamilton has implemented mandatory carded play across its gaming operations. Customers are required to use a player card when participating in gaming activities. This requirement supports AML/CFT obligations by enabling accurate transaction tracking, account monitoring, and customer identification in accordance with the AML/CFT programme.

8. Regulatory Compliance History

SCML, as the licensed operator of Skycity Casino Hamilton, was subject to a supervisory review conducted by the DIA between September 2022 and December 2023. Following that review, the DIA commenced civil proceedings in the Auckland High Court relating to AML/CFT compliance failures that occurred between February 2018 and March 2023. These failures related to risk assessment, the establishment and maintenance of an effective AML/CFT compliance programme, monitoring of accounts and transactions, the conduct of enhanced customer due diligence, and the termination of business relationships where required.

SCML admitted all five causes of action in the DIA’s statement of claim. In September 2024, the New Zealand High Court imposed a civil pecuniary penalty of NZ$4.16 million on SCML for these breaches. The DIA confirmed that there was no evidence to suggest that SkyCity was directly involved in money laundering or the financing of terrorism. The breaches were characterised as failures of compliance programme implementation and maintenance.

Following these proceedings, SkyCity Entertainment Group has undertaken measures to strengthen AML/CFT controls across its New Zealand casino operations, including at Skycity Casino Hamilton.

9. Age and Entry Requirements

Entry to the casino floor at Skycity Casino Hamilton is restricted to persons aged 20 years and over, in accordance with New Zealand law. Identity verification at entry serves both age verification and AML/CFT identification purposes where applicable.

10. Regulatory Authority Contact

The AML/CFT supervisor for Skycity Casino Hamilton is:

Department of Internal Affairs (DIA), Te Tari Taiwhenua
New Zealand

Customers who have concerns regarding AML/CFT compliance at Skycity Casino Hamilton may contact the DIA directly through its official channels.

11. Policy Updates

This policy reflects the AML/CFT obligations applicable to Skycity Casino Hamilton under the AML/CFT Act 2009 and is subject to amendment in accordance with changes to applicable legislation, regulatory guidance, or internal compliance requirements. Customers are advised to refer to the current version of this document when seeking information regarding AML/KYC procedures at Skycity Casino Hamilton.