Actually Col, I had a brief glimpse through the UKGC AML pdf, and the recommendations are guidelines for casinos to follow, and if the UKGC finds that a particular casino is not taking adequate steps regards AML, they may revoke the licence, so it is not strictly law, it's a bit of a grey area.
For example I could not find anything in the guide pertaining to having to play through a deposit 1x, only something about a criminal might park his funds in a casino account for a while, and later withdraw it, so something to be wary of... along those lines. But I think the commission is leaving it up to individual casinos to apply common sense, as there is nothing in black and white, as in 'law'.
With KYC, it may be more clear cut, and shouldn't really be a problem, for most people anyway.
the guidance should be read in conjunction with the laws surrounding the various factors though, identification should be done as part of the CCD anyway as you say. No casino is going to risk their license just beause someone doesn't have ID.
This is a list of whats acceptable from the UKGC
Documents issued by government departments and agencies that contain a photograph may be considered reliable. In practical terms, for face-to-face verification conducted by non-remote casinos, production of a valid passport or photo card driving licence should enable most individuals to meet the identification requirement for AML/CTF purposes. These documents will also confirm either residential address or date of birth.
6.63 Alternatively, government issued documents without a photograph which incorporate the customer’s full name may be used, supported by a second document, which is ideally also government issued, or issued by a public sector body or authority. This second document must also include the customer’s full name and either his residential address or his date of birth.
6.64 The following sources may, therefore, be useful for verification of UK-based customers:
• current signed passport
• birth certificate
• current photo card driving licence
• current EEA member state identity card
• current identity card issued by the Electoral Office for Northern Ireland
• residence permit issued by the Home Office
• firearms certificate or shotgun licence
• benefit book or original notification letter from the Department of Works and Pensions confirming the right to benefits
• council tax bill
• utility bill or statement (but not ones printed off the internet), or a certificate from a utilities supplier confirming an arrangement to pay services on pre-payment terms
• bank, building society or credit union statement or passbook containing current address (but not statements printed off the internet) - bank or credit cards alone will not be sufficient as these do not provide either residential address or date of birth
• confirmation from an electoral register that a person of that name lives at that address
• recent original mortgage statement from a recognised lender
• solicitor’s letter confirming recent house purchase or land registry confirmation of address
• local council or housing association rent card or tenancy agreement
• HMRC self-assessment statement or tax demand
• house or motor insurance certificate.
Its worth keeping a copy of that for any casino that gets arsey about stuff