Cash handling and anti-money laundering policy

Payment exclusions

• We do not accept cash.
• We do not currently accept Credit/Debit Cards
• We use a third party payment processor for Direct Debits.

If we receive any cash by mistake we must;

• Inform the customer that we do not accept cash
• Return the cash to the customer by special delivery
• Record the date received and date returned

We only accept payment via Direct Debit, standing order or cheque.

Payment by Cheque

• Cheques should arrive at all times attached to the application form, or accompanied by a cheque renewal form.
• Should they be separated then they should be matched by customer name. To verify this, the customer should be called to confirm the last 4 digits of the account number.
• Banking of any cheque payment will be made weekly, recording the date of banking against each cheque, name of payee and lottery player reference.

Payment by Standing Order/Direct Debit

• A copy will be made of the customer’s original mandate. For Standing orders, the original will be sent to the customer’s bank for processing. Bank’s will only accept and process original mandates. For Direct Debits, we will process them in accordance with Bacs rules. All mandates must be signed by the account holder. Every mandate will include the customer’s lottery player reference.
• Standing order and direct debit receipts come accompanied by the payment identifier. The payment identifier is the customer’s lottery player reference. The system automatically matches and imports these payments to the customer account and posts the relevant payment.
• Should a payment not match then the customer will be contacted to rectify.
• The customer will only be entered into a draw if they are in credit on their lottery account.
• All payments will be kept in the bank account relating to the charity lottery draw. This money will only be used for lottery draws, any balance being held remains the property of the lottery player until such time it has been used by lottery draws or refunded on request.

Suspicious transactions

• Staff are trained to identify any suspicious transactions (such as unusually large numbers of lottery ticket or chances)
• If our staff have a concern that a customer’s behaviour (signified for example by a sharp increase in their expenditure on lottery tickets or chances) may indicate suspicious behaviour, they will be trained to report the matter to the responsible person who will telephone the customer to discuss the matter, and report it to the police if suspicion remains. In severe cases, consideration may be given to barring the customer from participating in the lottery.

Annual Review

Tower Lottery Partnership will conduct an annual risk assessment in November.

This review considers current risks to the operator, and any new developments over the previous years which have increased/decreased those risks.

This review would address the following issues;
• The introduction of new technology (tablets for instances), or a new lottery (raffles etc.).
• New payment methods (Credit card, Pay Pal etc.)
• Changes in customer demographic (targeting different regions or groups that could contain higher incidences of crime).

Reviewed & Revised – April 2018