Reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) took effect on 31 March 2026. The reforms in AML/CTF Act together with the new Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (the Rules) marked a significant step towards a more risk-based compliance framework. AUSTRAC has warned that a purely procedural approach to compliance is not sufficient and instead emphasised that the purpose of the reforms is to help businesses better identify, assess and manage money laundering and terrorism financing risks.

Four months later, pubs, clubs and hotels should have completed the initial compliance exercise. AML/CTF Programs are to have been updated, risk assessments reviewed and policies and processes refreshed. Now, the most important question is, have these changes been operationalised and effectively implemented across the business?

Author: Bree Ryan, Senior Associate / Alexandra Hoskins, Principal

The AML/CTF Act and Rules require that compliance must become part of everyday decision-making rather than documents sitting on a shelf. In our experience, implementation is often where the greatest value is created but can also often fall short. A well-drafted AML framework provides the foundation, but its effectiveness depends on whether staff understand it, managers use it and governance processes support it.

How is implementation measured?

We consider venues should answer the following questions to determine the effectiveness of the AML/CTF framework.

1. Does our risk assessment reflect the risks the business reasonably faces?

Now that the new framework has been operating for a short period, venues should consider whether the risk assessment accurately reflects current business practices, customer behaviours and operational risks and realities. Are there any changes that need to be made:

• to the risk assessment to reflect operational requirements or changes to systems or processes; and

• are there any changes that have been implemented to process which need to be reflected in the training and implementation of the framework?

2. Are staff accurately and effectively identifying and escalating risk?

Transaction monitoring frameworks must be sufficiently rigorously detailed to specify all of the different ways transactions are monitored by the business as well as detail who is responsible internally, how frequent the type of monitoring occurs, what would result in an escalation to the AML/CTF Compliance Officer etc. Transaction monitoring relies on staff at different levels of responsiblity being able to identify unusual or suspicious activity and understand when escalation is required. Internal AML frameworks commonly identify concerns such as unusual transaction activity, structuring, third-party involvement and unexplained source of funds indicators as matters requiring further review.

The venue able to demonstrate that its front-line teams feel confident recognising those risks in everyday situations and are taking the appropriate action.

3. Is governance driving continuous improvement?

The reforms place ongoing responsibility on boards, senior management and AML Compliance Officers to oversee risk management and compliance effectiveness. Strong AML governance is not simply about oversight. It is about creating regular opportunities to review incidents, test controls, identify emerging risks and ensure lessons learnt are incorporated into business processes.

The AML/CTF Compliance Officer should be regularly reporting and reviewing the framework in line with the new AML/CTF Program and providing key performance indicator information to the board and senior management so they can conduct effective oversight and discharge their duties.

Operationalising the reforms

We consider the focus for venues should be on ensuring that they are embedding the framework into existing business operations to ensure the framework delivers a practical risk management tool. This may include:

• reviewing whether staff training remains relevant and engaging;

• testing escalation and reporting pathways;

• assessing whether transaction monitoring outputs are generating meaningful insights;

• regularly revisiting risk assessments; and

• ensuring management reporting supports informed decision-making,

Each of these activities must be conducted in accordance with the AML/CTF Program which has been adopted by the venue.

Looking ahead

The reforms introduced on 31 March 2026 signalled a clear shift towards a more risk-based approach to compliance. Four months on, the focus for many venues is moving from implementation to effectiveness.

The most successful AML frameworks are rarely the most complex. They are the frameworks that are understood, embedded and consistently applied across the business. For pubs, clubs and hotels, now may be an opportune time to undertake a practical review of how the reforms are operating in practice by undertaking an independent review for the purpose of the Act. Not simply asking whether changes were made, but whether those changes are delivering the outcomes they were intended to achieve.

If you are reviewing your AML/CTF framework, it may also be an opportune time to consider the broader range of your internal governance and customer-facing policies. Should you require further advice on updating or implementing your AML/CTF framework or other internal governance or customer facing policies, please reach out to Senet.

About Senet

Senet is a multidisciplinary Australian firm specialising in gambling and gaming law, regulatory compliance, and business advisory services. We are the largest specialist team in Australia and based in Victoria. Recognised globally as experts in our field, we understand Australia’s complex gaming legal and regulatory landscape, enabling us to guide clients through their compliance requirements across each state and territory. Our clients range from start-ups to publicly listed global operators, both nationally and internationally. Our team is deeply immersed in the industry, often sharing insights at public speaking events, and our principals have held executive roles in a global ASX-listed entity and a 'Big Four' advisory firm, giving us a unique perspective on the challenges our clients face.

If you have any questions or would like to discuss the topics covered in this article, please contact the team at Senet.

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