AUSTRAC AML / CTF PROGRAM

Transcription

1 AUSTRAC AML / CTF PROGRAM PART A PROGRAM The following document and Program applies to : A Wagering Operator accepting wagers ( Bets ) on thoroughbred racing events. 1. BUSINESS OVERVIEW The Business structure is that of a sole trader/partnership and is called 2. Introduction This document is the AML/CTF program adopted under section 81 of the Anti-Money Laundering and Counter Terrorism Act 2006 (Act) by The Business.

2 Money laundering (ML) is taking money from illegal services and cleaning it making it appear to be legally obtained. It is the processing of criminal profits to disguise their illegal origin. Terrorism financing (TF) includes the financing of terrorist acts, terrorists and terrorist organisations. The Act requires those involved in the gambling industry to: identify their customers before providing certain services; report certain transactions above a monetary threshold; and report suspicious matters. The Australian Government introduced these new laws to: reduce the risk of Australian businesses being misused for the purposes of ML or TF; bring Australia s existing AML/CTF system into line with international standards; and meet the needs of law enforcement agencies for targeted information about possible criminal activity and terrorism. 3. AML / CMF COMMITTMENT The Business recognises the objectives of the Act and its obligations under it. To the extent permissible by law, The Business will satisfy its obligations in a manner which is consistent with business efficiency, the requirements of other relevant laws and the best interests of those of The Business s customers who do not pose any material ML/TF risk. The Business s commitment on ML/TF risk is consistent with its commitment to adherence with all Wagering, Betting and Racing Act laws, other applicable laws and the standards of integrity required in the ownership, management and operation of gambling in The Business generally. Relationship with AUSTRAC Subject to complying with any specific timelines required by law, The Business will conduct all dealings with officers of AUSTRAC promptly and in good faith. All written requests and feedback by AUSTRAC, whether or not made pursuant to a specific statutory power of AUSTRAC, will be carefully considered by me as the AML/CTF Compliance Officer (CO). 4. ML / TF RISK ASSESSMENT The Business recognises, it engages in some activities that involve risks that require monitoring under AML CTF obligations.

3 These activities and associated risks can be broken into the following ; Customer Types Regular Clients / Account holders - Low Risk Visitors - Low Risk Designated Services Accepting Wagers - Low Risk Paying out Winnings - Low Risk Methods of Delivery Face to Face - Low Risk Telephone Betting - Low Risk Internet Betting - Not applicable JURISDICTION Domestic / Australia only - Existing gambling designated services Low Risk The Business has assessed the ML/TF risks in its gambling services as detailed in the attached Risk Assessment appendix. As the CO, I will conduct a periodic review of the ML/TF risks The Business faces. Proposed new designated services Prior to introducing any change to the way The Business s gambling or other designated services are delivered or in the technology for delivery of those services, I will assess the inherent ML/TF risk of that proposed new service method or technology and the ML/TF risk that might arise with different types of customers which can be anticipated. This will be done in order to consider whether any amendment to this program is desirable to materially improve the prospect of identifying, managing or mitigating ML/TF risks arising from the change. Risk rating methodology The following sets out how The Business rates its customers in relation to ML/TF risk. (i) Customers who do not fall within (ii) or (iii) below. This is the default rating which applies to the majority of customers whether they are known / identified or not. Low risk No further action required.

4 (ii) Customer who requests or receives a pay-out by cash, cheque or other means of $10,000 or more from winnings, credits from a winning wager Medium risk Action required: obtain Basic KYC Information; verify ID; enter information on Register; monitor customer and customers transactions; file threshold transaction report with AUSTRAC (iii) (a) Customer who is: known criminal; known money launderer or terrorist financier; known terrorist or politically exposed person; (b) Customer involved in suspicious matter; (c) Where suspicion about a customer s identity arises; or (d) Where suspicion about the source or beneficial interest, beneficial ownership or beneficial control of monies arises; or (e) Other circumstances or behaviours of customers identified as red flags in the risk assessment tool. High risk Action required (see paragraph 9 below for details): further KYC information; enhanced due diligence; enter information on Register; file suspicious matter report with AUSTRAC; monitor ; examine and verify KYC information on the non-individual entity (if applicable) Explanation Unless this program or a decision made under this program requires otherwise, all customers will be automatically rated as Low risk. This is the default rating.

5 A customer will be considered to be Medium risk or High risk if a risk rating performed under this program produces that result or if the CO assigns the customer that rating. Identified Medium and High risk customers will be listed in a ML/TF risk register (Register) which will be updated for any additional ML/TF risk information about that customer which The Business acquires. The Register will be part of the Records and be kept in a safe and secure location. I will consider each customer promptly after new ML/TF risk information is entered in the Register about that customer and consider whether the customer s risk rating should be changed. A. Actions for Medium risk patrons Where The Business has identified a Medium risk customer I will: obtain the customer s name, date of birth and residential address (Basic KYC Information); verify that information in accordance with Part B of the AML/CTF Program; enter the information on the Register; file a threshold transaction report with AUSTRAC (if required); and monitor the customer s transactions. B. Actions for High risk patrons Further KYC information Where The Business has identified a High risk customer or where the CO considers it useful, the CO will obtain further KYC information about a customer including: any other names or aliases by which the customer is known; country of citizenship or residence; occupation, employer or business activities, or the customer s source of funds or financial position. KYC information on the entity or person who is the source or in receipt of the primary customers funds If obtained, such information should be placed on the Customer Register. On Going Customer Due Diligence The Business will treat each dealing with a customer as a one-off. Our relationship with the customer finishes as soon as the customer leaves the racetrack or finalises the bet. If the customer were to re-visit in one week, 6 weeks or 6 months a complete new assessment of the customer profile risk and a decision whether KYC information would be required would be made at each visit to each of the racetracks that we operate at.

6 In addition, the change over of staff due to itinerant and casual staff, requires that all staff are instructed that for each AML / CTF issue a new customer ID and information must be obtained. The staff are instructed that any concerns must be raised immediately with me at the time. I will monitor the transactions that have taken place via the Wagering Monitoring software. I will decide when to apply Enhanced Customer Due Diligence, and The Business does not feel ECDD is necessary for lower risk customers. Enhanced customer due diligence (CDD) The actions required under Enhanced Customer Due Diligence are to be read in conjunction with Chapter 15 Ongoing customer due diligence Austrac ACT. Enhanced CDD must be applied in circumstances where: (a) (b) (c) (d) The Business has determined that the ML/TF risk is high; or a suspicion has arisen and a suspicious matter report has or should be lodged. Transaction monitoring (refer to 9. Below) has identified high risk, or unusual or suspicious behaviour warranting ECDD There is uncertainty as to the beneficial owners, or beneficial control. The Business have in place monitored systems and controls to identify and determine when and if further KYC information is necessary. The system and information is provided by the wagering software identifying unusual betting habits or patterns of behaviour. See transaction monitoring. Staff are also instructed to watch for unusual betting activity or behaviours such as placing bets on all runners or options in a race or event, selecting on option and doubling all bets until that option occurs. Staff should familiarize themselves with and be aware of the Customer Risk profile Matrix, and Risk Assessment Tool of customer attributes in appendix. Staff must also use the software s risk based systems and reports that identify unusual behaviour to help control when further KYC information is necessary. When staff have observed unusual betting activity or behaviour, (and note: much of this behaviour is banned by The Business in-house policies, adopted Code of Conduct and determined by VCGR to be against Best Practice policies in wagering, such as trying to corner all possible outcomes by backing all event runners), they must then identify those transactions using the monitoring software for follow up scrutiny and referral to me. To Mitigate any risk or possible occurrence of Suspicious Transactions It is House Policy that any payouts are also limited to $10,000 in cash with anything above that amount payable only by cheque. If the source of or proposed receipt of payout of wagering funds ie be cheque, bank deposit (methods other than cash) is not the same as the customer or to a nonindividual entity and suspicion arises as to the beneficial owner or controlling interest of

7 those funds then staff must carry out further KYC on the person or entity paying or receiving those funds to ensure there is a reasonable and an acceptable association with the customer. For each customer on the Register, I must consider whether any useful purpose would be served by conducting enhanced CDD. If that occurs, I will lodge a further suspicious matter report if necessary. Details of the enhanced CDD will also be entered on the Register. Ceasing to deal with High risk customers I will consider whether The Business should cease providing services to a High risk customer who is known to have engaged in money laundering or terrorism financing, or is currently at extreme ML/TF risk. 5. RISK AWARENESS TRAINING PROGRAM The Business s AML/CTF risk awareness training program will be delivered to all relevant employees. Part of the designated training program will include the requirements under the AML/CTF Rules. I will meet with New staff and ensure their induction has been complete and thorough. In summary, the program is designed to enable employees to understand: the obligations of The Business under the Act and AML/CTF Rules; the consequences of non-compliance; the type of ML/TF risks The Business might face and the potential consequences of such risk; and the processes and procedures set out in The Business s AML/CTF program that are relevant to the work carried out by the employee. Refresher Training In addition to Induction Training I also have Refresher training which is conducted annually and covers off the same elements as in Induction Training. I ensure that all staff are competent and understand their AMTCFL obligations by providing regular training and supervision. Employee due diligence program Any employee who is directly engaged in the provision of a designated service will be subjected to The Business s employee due diligence program. The program contains the following:

8 reference checks and review of employee employment history to determine whether, and in what manner to screen any prospective employee who, if employed, may be in a position to facilitate the commission of a ML or TF offence when providing services covered by this program. review of employee employment history to determine whether, and in what manner, to re-screen an employee when that person is transferred or promoted into a role from another wagering operator, and the system for when an employee fails, without reasonable excuse, to comply with any system, control or procedure established under this program, which is basically to remove that employee from the role until they can either be redeployed or re-trained subject to satisfactory standards. Employees who have no relevance to wagering operations are not covered by this program. For example, staff who only serve in administrative areas. If any relevant employee of The Business fails to comply with this program, the employee will be counselled by me and, where appropriate, scheduled for re-training. In circumstances of material breach of this program The Business will take more severe action, including dismissal or termination of the employee if appropriate. In addition to conducting Due Diligence on new employees I also conduct re-screening on existing employees when they move into an AML/CTF position. The screening would be the same as the induction screening, the process is the same as for new employees as outlined above. 6. GOVERNANCE The Business s AML/CTF Part A Compliance Program and subsequent amendments must be approved by me. 7. AML/CTF COMPLIANCE OFFICER As the AML/CTF Compliance Officer I am responsible for the overall management and monitoring the AML/CTF program. My responsibilities are; - AML/CTF Risk Awareness training for Business Staff - Consideration of any AUSTRAC feedback regarding the Businesss Risk Management performance - Ensuring continuing compliance with the Business s AML/CTF obligations. 8. AUSTRAC FEEDBACK All written requests and feedback by AUSTRAC, whether or not made pursuant to a specific statutory power of AUSTRAC, will be carefully considered by me as the AML/CTF Compliance Officer (CO). 9. ON GOING CUSTOMER DUE DILIGENCE The AML/CTF legislation requires The Business to monitor the patrons on an on-going basis in relation to the designated services (ie Wagering activities) and the paying out of winnings that are provided to those patrons. This includes on-going monitoring of

9 regular patrons, visitors, tourists and any other patrons who use the Business s gaming facilities. There are three main components on on-gong customer due diligence. These are: - Know your Client (KYC) information; - Enhanced KYC - Transaction monitoring program These components are discussed in detail in section 4, Risk Rating Methodology. 10. KNOW YOUR CUSTOMER As set out in our Part B program if the Business determines that a patron is a high or medium risk then our staff must collect additional KYC information as outlined in the enhanced Customer Due Diligence procedure. Situations which could occur where additional KYC must be collected includes : - Tip offs by other clients - Clients refusing to accept individual winnings (pay-outs), (trying to accumulate a large payout) - Large amounts of cash on a patron betting - Irregular or strange behaviours of customers - If a customer claims a payout when they are not the legitimate winner - If a customer has obtained or purchased a winner wager from another customer. - If a patron inserts a large amount of cash credits into their wagering account then cancels the credits and claims a payout following a period of minimal play - If a patron who regularly bets and whose average spend suddenly increases on certain days which is not consistent with Centrelink or pay day - Suspicion arises as to the beneficial owner or beneficial controlling interest of wagers. If any of these circumstances arise the matter must be immediately referred to me. 11. TRANSACTION MONITORING PROGRAM The Business has implemented a transaction monitoring program ( TMP ) which detects suspicious transactions including complex and unusual patterns of patron behaviour. Our TMP includes the following systems: - RVL Monitoring - The wagering software provides live regulatory and meter log reports of the wagers which are checked regularly by the AML/CTF CO and on demand if a suspicion arises - All phone bets are recorded. - All accounts are reviewed weekly by the CO. - All source of funds and Payee list is reviewed by the CO Reports of Transaction activity will be considered by me as part of the on-going review of this AML/CTF program All staff are trained in using the wagering software and part of their rostered duties is to check and monitor the transactions and performance. The purpose will be to identify suspicious matters (if any) which should be reported to AUSTRAC under this program.

10 The system should have regard to any complex, unusual or large transactions, which have no apparent economic or visible lawful purpose. For example, if a customer seeks to cash out after little or no play. The type of monitoring would include: observation by staff of customer behavior; review of reports to AUSTRAC; review of large cash transactions records, and review of the Register and cross checking of customer names with reports and records. Reports of transactional activity will be considered by the CO and/or CEO as part of the ongoing review of this program. 12. REPORTING OBLIGATIONS The Business has obligations to submit certain reports under its AML/CTF operations, these are: - Compliance Reports ( CR ); - Suspicious Matter reports ( SMR ); - Threshold transaction reports ( TTR ) Compliance Reports The Business recognises that it has an obligation to lodge an annual Compliance report to AUSTRAC This is done by the AML/CTF CO and lodged / submitted through Austrac Online between 1 January and 31 March each year. Suspicious Matter Reports The Business recognises that it has an obligation to submit Suspicious Matter Reports if there is a high risk situation or alternatively our staff suspects a patron or member of the public is acting in a suspicious manner in the Gaming area. Suspicious matters must be reported to Austrac within: - 24 hours if it is a Terrorism Financing matter - 3 business days if it is a Money Laundering Suspicion Under no circumstances can our staff tip off a person that they are subject to a suspicious matter report or that they have been reported to Austrac. Threshold transaction reports The Business recognises it has an obligation to submit TTR s under circumstances when winnings are paid out of $10,000 or more in CASH. The Business will pay out all winnings in excess of $10,000 by cheque and therefore it is unlikely that the Business will ever need to submit a TTR to AUSTRAC.

11 13. RECORD KEEPING The Business has an Obligation to retain all AML/CTF records in accordance with the AML/CTF Act. The Business retains all AML/CTF records for a period of 7 years. These are kept in hard copy format and secured appropriately on site. All records can be accessed quickly if required. The following AML/CTF records are retained: - Copies of all AML/CTF Part A and Part B programs - Copies of Amendments to AML/CTF Part A and Part B programs - AML/CTF transactions including all betting slips/dockets, records of winnings, payouts etc - KYC identification records - Suspicious matter reports - Annual compliance reports (soft copy only Austrac online) Resources & References AML/CTF Topic Resources Additional Information PART A 1 Business Overview and AML/CTF Obligations ML/TF Risk Assessment AML/CTF Rules Risk Awareness Training AML/CTF Rules Employee Due Diligence AML/CTF Rules Oversight AML/CTF Rules AML/CTF Compliance Officer AML/CTF Rules Independent Review AML/CTF Rules AUSTRAC Feedback AML/CTF Rules Ongoing Customer Due Diligence AML/CTF Rules Reporting Obligations AML/CTF Rules 8.9

12 Record Keeping AML/CTF Act Part 10 CUSTOMER IDENTIFICATION 1. Identification and verification procedures Identification A customer must be identified prior to the pay-out of winnings and/or accumulated credits, involving an amount of $10,000 or more irrespective of the form of payment. The customer will be required to provide Basic KYC Information, namely, full name, date of birth and residential address. This information must be put in the Register. Verification The customer s identity must be verified by one or other of the methods set out below. The method of verification must be recorded in the Register. This requires verification of a customer s full name plus date of birth or address by one of the following methods. Where it involves documents they must be original, valid, non-expired documents. Copies of the sighted documents must be kept in the Records. Method 1 - preferred Sighting: Passport; or Australian driver s licence; Proof of Age card; or

13 National identity card. Method 2 - alternative Sighting: Two forms of other identification (such as a birth certificate or birth extract, citizenship certificate, Centrelink pension card or any government financial benefits notice, Australia Tax Office notice, local government or utilities notice (where the notice contains the name and residential address of the customer)); and plus verification of the stated name and residential address against a check of the Sensis White Pages; and in the case of a payout of winnings of $10,000 or more, the payment must be by non-negotiable cheque made payable only to the customer. Unless the customer is a High risk customer, identity may be verified by me personally attesting to the identity of the customer, based on a previous verification. Discrepancies Any discernible discrepancy between a claimed identity and the offered documentation must be recorded and, if it relates to a circumstance other than a change of name on marriage or an obvious typographical error, must be subject to further enquiry of the customer (and a Record kept). 2. High risk customer verification Where a customer is rated as High risk, any verification or re-verification of the customer s identity must occur only by one of the following methods: sighting the customer s passport or Australian driver s licence; or if the customer does not have either of these documents, such combination of the documents referred to in The Business s AML/CTF Customer Identification Procedures. For non-individual entities, the ABN/CAN will be required as well as names of the Directors Until that time, The Business will not pay-out of winnings and/or accumulated credits, or award any prize, involving an amount of $10,000 or more. 3. Re-verification of identity Where The Business staff suspect on reasonable grounds that a customer is not the person who he/she claims to be, they must enter/flag the customer on the Register as a customer to be re-verified upon the next occasion occurs.

14 Until the customer s identity is properly verified, the customer will be considered and treated as Medium or High risk. I may decide to submit a suspicious matter report (refer to The Business s AML/CTF Suspicious Matter Reporting Policy).

15 AML / CTF corporate governance AML / CTF STATEMENT OF RESPONSIBILITIES 1. AML/CTF Compliance Officer (a) (b) (c) (d) (e) (f) (g) (h) (i) (j) Ongoing review of ML/TF risk. Keeping records required by AML/CTF program. Implementation of the Employee Due Diligence Program. Actions required under the AML/CTF program. Reporting to the CEO on implementation of the AML / CTF program. Preparing AUSTRAC annual compliance report. Filing other reports with AUSTRAC (as and when required). Liaison with AUSTRAC. Co-ordinating independent audit reviews of the AML / CTF program. Implementation of the Transaction Monitoring Program

16 APPROVAL OF AML / CTF PROGRAM Documents tabled: The Business s: AML / CTF program; ML / TF risk assessment; AML / CTF Compliance Officer APPROVAL OF AML / CTF PROGRAM As the pwner of The Business I hereby approve the attached AML / CTF program for The Business and will subject that program to oversight and review from time to time. Signed this day of 2015 By (full name): Title: Signature:

17 AML / CTF COMPLIANCE OFFICER DUTY STATEMENT / JOB DESCRIPTION Responsibilities: implementation of the AML / CTF program, including implementation of the employee due diligence program and the risk awareness training program; ongoing review of and reporting on AML / CTF risks to the business; reporting to senior management on the AML / CTF program; preparing and briefing mandatory reports to AUSTRAC, including: - annual compliance reports, - suspicious matter reports - threshold transaction reports liaison with AUSTRAC, including recording and responding to AUSTRAC feedback; and co-ordinating regular independent reviews of the AML / CTF program and implementing the results as determined by the governing board and senior management. Note the AML / CTF Compliance Officer may have other duties

18 Specimen AML / CTF customer identification procedures When must customer details be collected? AML / CTF CUSTOMER IDENTIFICATION PROCEDURES The Business must collect and verify information about a customer before paying out winnings and/or accumulated credits or the awarding of a prize on a gaming machine involving an amount of $10,000 or more. This must be done whether the payment is in cash or by cheque or other means. What must be collected? The minimum information which The Business must collect about a customer is the following details: full name, full residential address, and date of birth. This is called the basic KYC (know your customer) information. What must be verified? The Business must verify at a minimum: the customer s full name, and either of the customer s date of birth or the customer s residential address. How are customer details verified? This is done by checking the details provided by the customer against customer identification documents (ID). A list of ID that will be accepted by The Business management is in attachment A. Normally the only acceptable ID is an original. However, where the customer is Medium or lower risk, certified copies of ID will be acceptable. The ID must be checked to ensure that it is valid and has not expired. In the case of a Medium or lower risk customer only, an Australian passport that expired within the previous 2 years will be acceptable. You should also check to ensure that the ID has not been cancelled, forged, tampered with or stolen.

19 What if the customer can t provide id? If a customer is unable to provide documents covered by the list in attachment A, the Business manager or CEO or CFO should be consulted and the customer asked to produce other types of ID as set out in attachment B. Where a customer cannot produce any of the ID listed in attachments A or B, the Business manager or CEO must be consulted and will determine what ID is acceptable having regard to the ML/TF risk. Do I have to check anything else? There may be rare circumstance where you have no idea who a customer is and have a suspicion that the customer could be what is known as a politically exposed person. Refer to the Risk Assessment spreadsheet tool and the Customer Risk matrix and Customer Risk Attributable questions. In general terms, this means a person who is not an Australian and who is or was a prominent person in a foreign country (for example, a senior politician or military official). In that case, you should immediately consult with your manager. There may also be times when you must try to collect additional information about a customer because the Business believes the customer may have a higher risk of being involved in money laundering or terrorist financing. You will receive instructions from your manager on what to do in these cases. These cases arise when you observe Unusual or Suspicious Customer behaviour such as trying to play all numbers, more than one machine, back all horses or greyhounds in the one race. Basically where the actions show no apparent economic or viable lawful purpose. The Business s AML / CTF Compliance Officer should access an appropriate database to check whether person is apolitically exposed person (PEP), or to seek further external advice, eg. from the RVL, VBA or even legal assistance. A PEP is an individual who is or has been entrusted with a prominent public function in a foreign country, for example, a head of government, senior politician, senior judicial or military official, or senior executive of a state owned corporation or an important political party official. What if I am suspicious? If you have a suspicion that a customer may be involved in either money laundering or terrorist financing, the Business may have to report that suspicion to AUSTRAC. You must contact your manager to discuss your suspicions so that The Business management can decide on what the appropriate next steps should be. What do I have to record? Details of the ID which is accepted must be entered into the AML / CTF Register kept by the Business s AML / CTF Compliance Officer. For example, the type of I.D., its number and its expiry date. You should also keep copies of the ID shown to you. The copies must be retained in a safe, secure place and kept for 7 years from the date of the last transaction with that particular customer. You should be mindful of obligations under privacy laws and, where in doubt, consult with your manager.

20 Attachment A (as referred to in Customer Identification Procedures) Reliable and independent documentation specified in the AML / CTF Rules (see reference materials in Attachment C) Type of identification document PRIM has a photograph Passport Australian driver s licence Proof of Age card National identity card from a foreign country NONPRIM does not have a photograph Birth certificate or birth extract Citizenship certificate Pension card issued by Centrelink SEC Notice of government financial benefits Notice from ATO Notice from local government Notice from utilities provider

21 Attachment B Reliable and independent documentation not specified in the AML / CTF Rules Type of identification document Credit/debit card (with photo) Learner s permit (with photo) Medicare card no photo NSW (or other State) photo card issued by RTA Shooter s licence with photo University/TAFE ID card with photo Type of identification document ACN ABN Copy of ASIC Company certificate Name of Directors or Trustee Non-Individual Entity Copy of Bank Statement Copy of ATO RBA (running balance account) Copy of ATO notice

22 Reference materials Attachment C Definitions of reliable and independent documentation AML / CTF Rules Appropriate ID includes but is not limited to: an original primary photographic identification document (PRIM); or an original primary non-photographic identification document (NONPRIM); and an original secondary identification document (SEC) An explanation of each of these categories is set out below. Note: These are not exhaustive definitions of the type of id that the Business can rely on. The Business may rely upon other documents not listed above as reliable and independent documents, where that is appropriate having regard to ML / TF risk. PRIM stands for: Primary photographic identification document which means any of the following: (k) (l) (m) A licence or permit issued under a law of a State or Territory or equivalent authority of a foreign country for the purpose of driving a vehicle that contains a photograph of the person in whose name the document is issued. A passport issued by the Commonwealth. A passport or a similar document issued for the purpose of international travel, that: (e) (f) (g) contains a photograph and the signature of the person in whose name the document is issued; is issued by a foreign government, the United Nations or an agency of the United Nations; and if it is written in a language that is not understood by the person carrying out the verification - is accompanied by an English translation prepared by an accredited translator. (n) (o) A card issued under a law of a State or Territory for the purpose of proving the person s age which contains a photograph of the person in whose name the document is issued. A national identity card issued for the purpose of identification, that: (a) (b) (c) contains a photograph and the signature of the person in whose name the document is issued; is issued by a foreign government, the United Nations or an agency of the United Nations; and if it is written in a language that is not understood by the person carrying out the verification - is accompanied by an English translation prepared by an accredited translator.

23 NONPRIM stands for: Primary non-photographic identification document which means any of the following: (p) (q) (r) (s) (t) A birth certificate or birth extract issued by a State or Territory. A citizenship certificate issued by the Commonwealth. A citizenship certificate issued by a foreign government that, if it is written in a language that is not understood by the person carrying out the verification, is accompanied by an English translation prepared by an accredited translator. A birth certificate issued by a foreign government, the United Nations or an agency of the United Nations that, if it is written in a language that is not understood by the person carrying out the verification, is accompanied by an English translation prepared by an accredited translator. A pension card issued by Centrelink that entitles the person in whose name the card is issued, to financial benefits. SEC stands for: Secondary identification document which means any of the following: (u) A notice that: (d) (e) (f) was issued to an individual by the Commonwealth, a State or Territory within the preceding twelve months; contains the name of the individual and his or her residential address; and records the provision of financial benefits to the individual under a law of the Commonwealth, State or Territory (as the case may be). (v) A notice that: (g) (h) (i) was issued to an individual by the Australian Taxation Office within the preceding 12 months; contains the name of the individual and his or her residential address; and records a debt payable to or by the individual by or to (respectively) the Commonwealth under a Commonwealth law relating to taxation; (w) A notice that: (j) (k) (l) was issued to an individual by a local government body or utilities provider within the preceding three months; contains the name of the individual and his or her residential address; and records the provision of services by that local government body or utilities provider to that address or to that person.

24 Customer signage/brochure ANTI-MONEY LAUNDERING and COUNTER-TERRORISM FINANCING ACT 2006 CUSTOMER IDENTIFICATION RULES The Australian Government has introduced legislation which imposes a number of obligations on The Business in relation to customer identification. The Business is required to obtain a standard of customer identification suitable to satisfy the terms of the legislation. If you inquire about or ask to receive winnings of $10,000 or more in cash, you will be asked to give your full name, residential address and date of birth. You will also be asked to produce identification that verifies your name and either your residential address or date of birth. Payouts are limited to $10,000 maximum and the balance over $10,000 is payable by cheque. The best type of identification documents are a passport, Australian driver s licence, proof of age card or national identity card (from overseas). If you do not have these documents, please speak to Management. If you can t produce identification of this type or which is otherwise suitable to the Business s management, the law requires the Business not to proceed with the transaction until such time as you do.