You may have heard there are updates coming to the Anti Money Laundering and Counter Terrorism Financing (AML/CTF) legislation that will impact pubs and clubs with 15+ gaming machines.
The rumours are true!
As Pubs & Clubs are already considered a designated service under AML/CTF legislation, the changes are minor but important for existing compliance obligations.
These changes include:
- Venues must have a risk assessment that is tailored specifically to the venue and the risks the venue may realistically face (main considerations are customers, Gaming Monitor Operator Programs/controls, and staff)
- Modifications to the AML/CTF program to reflect risk assessment
- Appointment of a designated, fit and proper AML/CTF compliance officer – this person must be registered as the venue’s compliance officer with AUSTRAC and must implement the venue’s AML/CTF training program of all staff.
- The role of governing bodies and/or senior management in overseeing risk and compliance has been expanded (the buck stops with the governing body of a venue).
- Enhancement of AUSTRAC’s regulatory powers including the authority to issue civil penalty orders, enforceable undertakings, infringement notices, and remedial directions for entities which are non-compliant.
- Venues must establish appropriate AML/CTF policies to manage and mitigate the ML/TF risks identified and comply with all AML/CTF obligations. If the proliferation financing risk is low and is appropriately addressed by policies related to money laundering and terrorism financing, venues won’t have to implement specific counter-proliferation financing policies.
- Adjustments to reporting form content
These changes come into effect on 31 March 2026.
New reportable details for SMRs and TTRs
The new Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 expand the reportable details required in suspicious matter reports (SMRs) and threshold transaction reports (TTRs).
From 1 July 2026 to 30 March 2029 current reporting entities will have the choice to submit an SMR and TTRs using the current form, or a new form that requires you to provide new information.
This will only apply if you were on the Reporting Entity Roll on 30 March 2026. New regulated entities cannot apply to enrol before 31 March 2026.
Training available!
Need AML/CTF training or staff? CTW provides easy to access and cost-effective online training.
Need AML/CTF training for managers? CTW provides comprehensive, easy to access online training for managers.
Interested in learning more about CTW’s Business Dashboard to make it easy for your venue(s) to procure and manage training for staff? Email us!