Compliance Question and Answers

What is an AML/CTF Program?

An AML/CTF Program specifies how you meet AUSTRAC compliance with AML/CTF legislation. It is a written document outlining the processes and procedures you have in place to identify, mitigate and manage the risk of your products or services being used for money laundering or terrorism financing. Your Program needs to address the appropriate levels of risk your business may face.


Do I need an AML Program for my Pub, Hotel or Club?

If you are a Hotel, Pub or Club holding more than 15 machines you are required to hold an Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program.


If you are part of a group of related hotels, pubs and clubs that collectively is licensed to have more than 15 EGMs, you need an AML/CTF Program.


How many gaming machines can I have before I need an AML program?

If you licence 15 or less gaming machines you are not required to have an AML Program. If you are licenced for 16 or more gaming machines you must have an AML/CTF program.


What are my AUSTRAC requirements if I have 15 or less gaming machines?

If you are licensed to operate 15 or less EGMs across all of your venues, you are not required to:

  • Hold an AML/CTF program;
  • verify customer identification for winning payouts; or
  • submit Threshold Transaction Reports (TTRs).

However, you are required to:

  • report suspicious matter reports (SMRs)
  • undertake record keeping
  • enrol your business with AUSTRAC


How do I get an AML Program?

To ensure the AML/CTF Program is written correctly and covers all basis it is highly recommended you outsource this service to an AML Program provider. The AML Company can provide you with an AML/CTF Program that is relevant to your Hotel, Pub or Club. We have taken the 400+ pages of the Anti-Money Laundering and Counter-Terrorism Financing Act and condensed it down to an AML program that is suitable for the hotelier, pub and club industry.


Alternatively, if you want to try writing your own AML Program, below is a brief checklist of what your AML Program requires:

  1. Appoint an AML/CTF Compliance Officer
  2. Describe your Employee Due Diligence Program
  3. Describe your AML/CTF risk awareness training program
  4. Respond to AUSTRAC feedback
  5. Establish regular independent reviews of your AML/CTF program
  6. Document ongoing customer due diligence
  7. Document your reporting procedures
  8. Collect and verify ‘know your customer’ (KYC) information (Part B AML/CTF program)
  9. Adopt the AML/CTF program and ensure ongoing oversight


Do I need to register with AUSTRAC?

If you are unsure and would like to check if you need to enrol with  AUSTRAC, you can call The AML Company on 02 9544 7044 and we can assist you with your query.  Or alternatively, you can use the  AUSTRAC web tool to see if your business requires AUSTRAC registration.


How do I enrol my Hotel, Pub or Club with AUSTRAC?

The easiest way to enrol your business with AUSTRAC is electronically via their online portal.


Who should the AML/CTF Compliance Officer be?

It is recommended you appointment someone from Management or the Owner of the Hotel, Pub or Club to be the AML/CTF Compliance Officer.  The AML Compliance Officer is the main point of contact for AUSTRAC and your employees for Anti-Money Laundering and Counter-Terrorism Financing matters.


What is an Employee Due Diligence Program?

The employee due diligence program describes the businesses process and procedures on screening employees and prospective employees that will be in a position to facilitate Money Laundering and Terrorism Financing (ML/TF) risks.  The program must contain appropriate procedures to manage employees to fail to comply with AML/CTF rules and regulations.


What AML training do my staff need to do to remain AUSTRAC Compliant?

Staff Training on AML/CTF must explain:

  • your obligations under the AML/CTF Act and the consequences of non-compliance
  • the types of ML/TF risk your business may face and the potential consequences of these risks
  • the processes and procedures in your AML/CTF program relevant to the work carried out by your employees.


AML/CTF AUSTRAC Staff Training Provider

To remain AUSTRAC Compliant it is a requirement that staff training, specifically on gaming machines and your AML/CTF Program is conducted on a regular basis.  RCA Group provides staff training on AML/CTF in a simple online format.


What is the penalty if I don’t comply with AUSTRAC regulations?

The consequence of non-compliance with the AML/CTF Legislation is severe.  The Federal Court may order the maximum penalty of $4.2 million (if the owner is individual) or $21 million (if the owner is a company).

In addition, criminal penalties can be imposed on certain AML/CTF obligations.


What is the penalty if I don’t submit an AUSTRAC Compliance Report?

If you don’t submit a compliance report when required, you can be fined 12 penalty units, or 60 penalty units if you are a body corporate. – KIRK PUT IN $$ VALUES


What do I need to do to remain compliant with AUSTRAC?

  1. Hold an up to date AML/CTF Program;
  2. Conduct staff training on AML/CTF that is specific to your AML Program;
  3. Perform an Independent Review of your AML/CTF Program regularly.
  4. Submit your AUSTRAC Compliance Report prior to the 31 March deadline every year.


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.