Are you AML/CTF Audit Ready?

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AUSTRAC have been in the news over the last 18 months for the successful prosecution of Tabcorp and Commonwealth Bank of Australia’s anti-money laundering and counter-terrorism financing laws.
Tabcorp were fined $45 million for breaches of the AML/CTF Act including a $1 million fine for not reporting suspicious matters on time. Commonwealth Bank were fined $700 million for 53,750 breaches of the Act.
AUSTRAC CEO Nicole Rose PSM said this penalty will cause industry to take note and that anti-money laundering and counter-terrorism financing (AML/CTF) will become a regular talking point in boardrooms of financial institutions across the country.
“Compliance with the AML/CTF Act is a serious matter. Money laundering, terrorism financing and serious financial crime are very real issues with very real impacts on the lives of everyday Australians,” Ms Rose said.
While CBA are in the financial sector, the club and pub sector have similar obligations under the AML/CTF Act.
Every year, your venue needs to ensure that your reporting obligations to AUSTRAC regarding AML/CTF Compliance are finalised before the closing date of March 31st.
If AUSTRAC turned up and audited you today, would you be ready?
It largely depends on the size of your gambling (gaming and betting) operation but the AML/CTF Act places a number of obligations on venues when they provide designated services such as electronic gaming machines and betting facilities.  These include:

  • Enrolling and/or registering the venue with AUSTRAC (and keeping the details up-to-date)
  • Customer identification and verification of identity requirements
  • Record keeping requirements
  • Establishing and maintaining an AML/CTF compliance program
  • Ongoing customer due diligence and reporting (suspicious matters and threshold transactions)
  • Employee due diligence requirements including reference and police checks

Getting your AML/CTF review locked in early will ensure you not only save money, but you will have your required documents ready, and avoid the usual wave of last-minute reviews in March. Come January next year, we will organise the best time to conduct your review and you won’t have to worry about it again until then!
Contact Michelle, Safety and Compliance Advisor to find out how we can design a customised solution for your venue and help you avoid a stressful AUSTRAC situation. Call her today on 0401 014 619 or email Michelle at

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