Anti Money Laundering Policy

1. Introduction

How we use your data (Data Protection)

Woking and Sam Beare Hospices are charities, registered in England (Reg. Charity No: Woking 1082798 Sam Beare 1115439).

Woking and Sam Beare Hospices set out to provide care and support to the families and children who suffer from life limiting illnesses throughout Surrey; these services are provided completely free of charge.

2. Purpose and Scope

Woking and Sam Beare Hospices therefore continually seeks to raise or generate the requisite funds to finance its services. Such finance is raised or generated through charitable giving, fund raising events, its charity shops and membership / participation in its weekly lottery and occasional raffles. In order to minimise its operating costs Woking and Sam Beare Hospices will also encourage the continuing use of, and growth of, its network of volunteers.

3. Duties and Responsibilities

Crime prevention is implicit in all aspects of lottery management. Staff and volunteers working with the Lottery & Raffles are trained to identify unscrupulous behaviour at induction. This may include, but is not limited to, money laundering, illicit credit and identity fraud. Suspicious or criminal behaviour is to be reported to the Lottery and Raffles Manager immediately and the police informed, where appropriate.

Any attempt by a player to pay in advance for membership longer than one year and/or buy 10 or more weekly subscriptions and/or buy more than 20 single tickets in one transaction will require express authorisation from the Lottery & Raffles Manager.

Written applications to purchase Lottery tickets/subscriptions by debit card require a signature confirming the cardholder is authorised to use the card. Tickets/ Subscriptions purchased by debit card are not entered into the lottery draw until payment has been received from the card to guarantee the card details are genuine.

Woking and Sam Beare Hospices commits to the protection of the business from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime

3.1. Lottery schemes

Woking and Sam Beare Hospices will refuse to be associated with any proposed lottery scheme or other gambling activity that may breach the law.

3.2. Contractors/agents

3.2.1. Woking and Sam Beare Hospices will refuse to contract with any contractors or agents who Woking and Sam Beare Hospices suspects may be associated with any potential or actual criminal activities.

3.2.2. Woking and Sam Beare Hospices will only use suppliers who are licensed by the Gambling Commission.

3.2.3. Woking and Sam Beare Hospices will require all contractors to:
(a) obtain references from all prospective employees and self-employed agents that are likely to be associated with Woking and Sam Beare Hospices gambling business.
(b) monitor their staff and self-employed agents on an ongoing basis, particularly regarding their direct or indirect association with potential criminal activities.

3.2.4. Woking and Sam Beare Hospices will only use gambling software (a Random Number Generator (RNG) produced by suppliers who have been licensed by the Gambling Commission to manufacture, supply, install or adapt gambling software to promote a lottery.

3.2.5. If Woking and Sam Beare Hospices determines that user interfaces will be required in order to enable customers to directly access its gambling facilities remotely and the necessary software development work needs to be sub-contracted to a third party, then Woking and Sam Beare Hospices will include terms that state that any such user interface shall comply with the Gambling Commission’s technical standards for remote gambling systems

3.3. Woking and Sam Beare Hospices may contract third party agents

3.3.1. Woking and Sam Beare Hospices will require third party agents to reference all prospective canvassers who are likely to be associated with Woking and Sam Beare Hospices gambling business. Woking and Sam Beare Hospices will require third party agents to maintain ongoing monitoring of all staff, particularly with a view to their direct or indirect association with potential criminal activities.

3.3.2. Woking and Sam Beare Hospices will require third party agents to ensure that they report any actual or suspected criminal activities to the police.

3.3.3. Woking and Sam Beare Hospices will require third party agents to ensure that staff involved in promoting lotteries or selling lottery tickets face to face are trained to a satisfactory standard to ensure compliance with Woking and Sam Beare Hospices gambling policy and procedure.

3.4. Prospective customers/actual customers

3.4.1. Woking and Sam Beare Hospices will not enrol any person into any of its lottery schemes if that person is suspected of any potential or actual criminal activities.

3.4.2. Woking and Sam Beare Hospices will advise customers in writing of their weekly lottery membership status and procedures associated with lottery payments.

3.4.3. Woking and Sam Beare Hospices will ensure that it reports any actual or suspected criminal activities to the police.

4. Monitoring Compliance and Effectiveness

Compliance and effectiveness will be monitored on an on-going basis by the Lottery Manager.

Non-compliance will be dealt with by the Lottery Manager in the first instance and then escalated to the Financial Controller, who is the Money Laundering Reporting Officer, in the second and finally to the Chief Executive Officer.

Addendum as at 10.03.2022

As a result of the UK government’s further sanctions against Russia, extra vigilance will be adopted whenever there is a perceived risk of conducting any third party, business or customer relationships which are associated with Russia and any of the sanctioned banks or entities. As a society lottery this risk is considered to be low.