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ECDD Process

All businesses offering a designated service must have an AML/CTF program to meet their compliance. Most importantly, all Hotels and Clubs with more than 15 gaming machines must have an appropriate program. Additionally, the program must be tailored to the individual business.

Following the implementation of the program, the compliance officer (generally the General Manager or the Licensee) is responsible for ensuring that all items outlined in the program are adhered to. To clarify, ensuring compliance with the program is critical and involves management oversight, training, and in most cases, independent reviews.

AML/CTF Program

Key components of the program that should be regularly reviewed or assessed are as followed:

  • Programs must be risk-based, and regular reviews should check to ensure the risk assessment in the program reflects the current business.
  • Know Your Customers (KYC) rules must be strictly adhered to.
  • The Transaction Monitoring Procedures (TMP) should be clearly defined procedures and should outline daily checks.
  • Clear procedures that facilitate the identification and reporting of suspicious matters.
  • The compliance managers must have appropriate authority to carry out his/her duties as they pertain to AML/CTF.
  • All staff must be trained (note training must be tailored to each designated service).

Note: These are some but not all of the areas that should be reviewed.


All Hotels and Clubs must complete an online questionnaire for AUSTRAC annually. This report is due by March 31st of each year. In order to complete the questionnaire, the compliance manager must ensure that the business’s AML/CTF program is complied with. Importantly, non-compliance can result in significant fines.

Should a Hotel or Club require assistance reviewing a program or compliance with the program, RCA  Group can assist. To clarify, RCA group is a boutique company that specialises in assisting Pubs and Clubs in managing their Anti-Money Laundering and Counterterrorism Terrorism (AML/CTF) needs.

Our focus is on ensuring that our clients meet their AUSTRAC obligations. For example, we work to ensure Pubs and Clubs understand AUSTRAC regulations pertaining to gaming machines. In addition, each of our clients reviews their program on a regular basis.  During the review, we meet with the venue’s General Manager or Licensee. Additionally, we work with the Compliance Manager to review and/or implement policies, procedures, and systems to facilitate the ongoing management of AML/CTF risks.

AML/CTF programs should be developed using a risk-based approach. RCA Groups review will assess the risks identified. Our methodology is not based on one size fits all.  Our aim is to assist clients in making compliance with AUSTRAC as seamless as possible. RCA Group has been working with Pubs and Clubs in NSW and QLD for 10 years. Following the review of a program, we are available to assist clients 7 days a week.

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