Compliance Report and Independent Review

Title slide for a presentation: 'Compliance Report and Independent Review' by RCA GROUP, dark blue background with cyan borders and footer rcagroup.com.au.
ECDD Process

The AUSTRAC Compliance Reporting period is approaching and it’s time to start thinking about conducting an independent review and completing your compliance report.

Who needs to report?

  • Venues that are licensed for 16 or more electronic gaming machines.
  • Member of a designated business group (DBG)

Independent Review

An independent review assesses Part A of your AML/CTF program. It checks that you’re complying with your program and the program is still suitable for your business.

For example, the areas the review should examine include:

  • whether Part A of your AML/CTF program is current and properly assesses that your policies and procedures are adequate to manage your money laundering/terrorism financing risks
  • any changes to your money laundering/terrorism financing risk profile
  • any changes to your AML/CTF practices and policies
  • how well do your employees understand and comply with your AML/CTF program?
  • how well has the business responded to previous recommendations
  • whether your AML/CTF employee training program is adequate and effective
  • whether your compliance officer has enough seniority and authority to adequately perform their duties
  • how well your transaction monitoring systems are working in identifying suspicious matters

Compliance report

Once your independent review has been conducted, you must complete and submit the compliance report between the 2nd of January and the 31st of March. Subsequently, all questions in the AUSTRAC report refer to your business activities from 1st January to 31st December.

Do penalties apply for failing to submit an AML/CTF compliance report?
If you don’t submit a compliance report when required, you can be fined 12 penalty units ($2,520) or 60 penalty units ($12,600) if you are a body corporate. Giving false or misleading information in your compliance report is a criminal offence.

We can assist you with your AML/CTF requirements:

Contact us on:
Email enquiries@rcagroup.com.au
Web RCA Group — rcagroup.com.au

2026 Update

This article was originally published before the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 commenced on 31 March 2026. Key changes affecting venues include:

  • New sight-and-record approach to customer identification
  • Requirement to appoint a fit and proper compliance officer by 30 May 2026
  • Expanded penalties — up to $33 million per contravention

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