Extra AML/CTF Vigilance required
Got poker machines, Keno or a TAB?
Then you need to increase your vigilance of anti-money laundering and counter terrorism finance activity.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (the Amendment Act) passed the Parliament on 29 November 2024 and most of the changes will commence on1 July 2026. However, many of the amendments impacting clubs and pubs with gaming machines and wagering services will commence on 31 March 2026. The Amendment Act is introducing new designated services (Tranche Two Entities), impacting other industries including real estate professionals, dealers in precious metals and precious stones and professional service providers such as lawyers, conveyancers, accountants, trust and company service providers.
Contrary to popular belief, the 2022 NSW Crimes Commission Report into Money Laundering in Pubs and Clubs stated:
Finding 5
Using EGMs to clean large quantities of dirty money is high risk and inefficient.
Accordingly, while it is occurring, it is not widespread.
Project Islington Report Page 32
There was recognition that some people were gambling by spending proceeds of crime, or in fact, indulging in criminal activities to fund their gambling, but this too is not laundering but just gambling.
In venues across the country, there are no doubt small businesses, operating with cash, who may use ‘gaming wins’ to avoid paying tax, so laundering on a small scale may be a fact of life.
Changes to AML/CTF Programs

The Department of Home Affairs provides the following guidance -
The revised AML/CTF program obligation includes:
- an overarching risk assessment to consider the money laundering, terrorism financing and proliferation financing risks the reporting entity may reasonably face
- proportionate risk mitigation measures to respond to the risk assessment
- a new simplified reporting group concept to allow reporting entities to manage and mitigate common risks more efficiently
- the roles and responsibilities of a reporting entity’s governing body and AML/CTF compliance officer
- simplified obligations for Australian companies operating overseas through a foreign branch or subsidiary of an Australian reporting entity.
For clubs, pubs and entities operating gambling and gaming machines, the other areas of focus include:
- more detailed risk assessments to identify potential opportunities for money laundering and terrorism financing
- increased levels of Customer Due Diligence (CDD)
- the exemption threshold for undertaking CDD will be lowered from “less than $10,000 to less than $5,000” (aligning with legislated maximum cash payouts in NSW and the international Financial Action Task Force [FATF] threshold)
- changes to the ‘Tipping Off’ offence intended to prevent the disclosure of information where it would, or could, reasonably prejudice an investigation

Generally, AUSTRAC has also gained addition information gathering powers including –
- a new examination power, to enable AUSTRAC to obtain relevant information needed to make enforcement decisions and obtain evidence to be used in AML/CTF court proceedings
- a new notice to produce power, to allow AUSTRAC to request information or documents and support the AUSTRAC CEO to carry out FIU functions under the AML/CTF Act
- a new ‘authorisation to produce’ to ensure that co-operative entities are not exposed to undue legal risk by virtue of voluntary cooperation with AUSTRAC, including through the Fintel Alliance
Impact on clubs and pubs
Whilst the amendments are relatively minor, the intent from AUSTRAC is clear. Greater due diligence is required for all reporting entities offering designated services. If you have any number of gaming machines and / or offer wagering services you need to -
- Enrol with AUSTRAC.
- Develop and maintain an AML/CTF program tailored to their business.
- Conduct initial customer due diligence.
- Conduct ongoing customer due diligence.
- Report certain transactions and suspicious activities.
- Make and keep records.
Recent press coverage of investigations into the club sector have raised the level of attention required by all clubs and pubs to ensure –
- You have a compliant AML/CTF program, audited at least every two (2) years
- You conduct thorough risk assessments on a regular basis
- Ensure all staff involved are fully trained in AML/CTF Awareness, as well as directors doing their AML/CTF Oversight training
- Ensure thorough and ongoing customer due diligence
- Effective monitoring and reporting of suspicious matter transactions, focusing on the reduced threshold of $5,000
As with many of the legislative protections we must comply with, to minimise harm and prevent money laundering and terrorism financing, the diligent application of the existing requirements and these enhanced reforms are essential for your organisation. Do what you need to do and you can safely continue to provide your services, knowing your compliance is your protection from potential investigations and penalties under the AML/CTF legislation.
Whilst AUSTRAC does not endorse consultants per se, there are specialist organisations who can assist you to meet your compliance in this area, helping you to interpret and contextualise the AUSTRAC templates (for programs) and meet all legislative requirements.
For more information or assistance to address concerns with your AML/CTF program, contact Ron Browne ron@extrapreneurservices.com.au 0414 633 423