AML/CTF Requirements for Pubs and Clubs

AML/CTF Requirements for Pubs and Clubs
• All Pubs and Clubs must have an AML/CTF Program tailored specifically for their business.

• Report customers who have a high number of gaming payouts. Special consideration should be given to those customers receiving winnings by cheque over a specific period. Monitoring customer winning should be part of the Transaction Monitoring Program (TMP).

• Monitor your venue for suspicious activity. This includes, but is not limited to:
o Buying winning tickets
o Asking for a cheque to be written in somebody else’s name
o Regularly bringing large amounts of cash to gamble
o Not playing machines in a normal pattern
o Always receiving winnings by cheque
If these behavior types are identified, the AML/CTF Compliance Officer should consider submitting a Suspicious Matter Report (SMR) to AUSTRAC.

• Keep your enrolment details with AUSTRAC up to date. A business is required to advise AUSTRAC of any changes to the business within 14 days.

• Maintain accurate electronic records of all transactions

• Maintain accurate records of all customers receiving a cheque payout

Should a Hotel or Club require assistance implementing an AML/CTF Program or a component of the Program into their venue, The AML Company can assist. We are a boutique company that specialises in assisting Pubs and Clubs in managing their Anti-Money Laundering and Counter-Terrorism needs. The focus is on ensuring that our clients meet their AUSTRAC obligations. We work to ensure Pubs and Clubs understand AUSTRAC regulations as they pertain to gaming machines. Each of our clients implements an AML/CTF Program. Programs are implemented with the Pub or Club on a face-to-face basis. During the implementation, we will meet with the venue’s General Manager or Licensee. We work with the Compliance Manager to implement policies, procedures, and systems to facilitate the ongoing management of AML/CTF risks. All programs are developed using a risk-based approach. Our methodology is not based on one size fits all. We aim to assist clients in making compliance with AUSTRAC as seamless as possible. The AML Company has been working with Pubs and Clubs in NSW and QLD for 10 years. Following the implementation of a program, we are available to assist clients 7 days a week.


The AML Company are experts in Pub and Club AML/CTF compliance. We offer cost-effective and compliant AML/CTF Program solutions to Pubs and Clubs in Australia.
We have been providing AML/CTF compliance programs to the pub and club industry for over 15 years. The AML Company is a boutique company that has provided Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Risk Analysis to Clubs, Pubs, and Financial Institutions for the past 15 years.  Our business focus is on AUSTRAC regulations as they pertain to gaming machines within Pubs and Clubs. We aim to make compliance with regulations as easy as possible for our clients.

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