AML/CTF Compliance for Gaming Venues: Essential Questions When Selecting Advisors and Independent Reviewers
The March 2026 Compliance Reporting Deadline
Significant reforms to Australia’s AML/CTF regime will take effect from 31 March 2026, impacting all existing reporting entities.
These reforms are designed to uplift Australia’s responsiveness to financial crime and to meet global best practices and standards set by the Financial Action Task Force (FATF).
We have highlighted some of the important aspects of these changes in a separate article here and recommend that gambling operators commence reviewing their existing arrangements in advance of the quickly approaching deadline.
The Role of Independent Advisors in Your Compliance Framework
AUSTRAC recognises the value independent advisors bring to gaming venues through:
Analysis of money laundering and terrorism financing risks specific to venue operations
Guidance on regulatory obligations under the AML/CTF Act
Development of tailored ML/TF risk assessments
Creation of venue-specific AML/CTF programs
Staff training aligned to compliance requirements
Independent program reviews at regular intervals
While engaging external advisors can support effective compliance, venues remain legally responsible for meeting their obligations. Selecting the right advisor requires careful consideration of expertise, methodology and approach.
Recent Regulatory Findings: What AUSTRAC Has Observed
Following compliance assessments across the sector, AUSTRAC has identified areas requiring uplift, particularly regarding:
Quality and depth of AML/CTF programs
Substantiveness of ML/TF risk assessments
Depth of analysis in independent reviews
The regulator has noted concerns about advisors relying on generic, template-based approaches that fail to reflect the actual risks venues face or the controls they have implemented.
Understanding your position: Reporting entities remain legally liable regardless of advisor involvement. When non-compliance is identified, enforcement actions and penalties apply to the venue itself.
Six Critical Areas to Examine When Engaging AML/CTF Advisors
1. Program Tailoring Beyond Templates
What AUSTRAC has found: During venue assessments, operators frequently did not understand or agree with risks outlined in template-based assessments. Some programs referenced controls not in use or ineffective in practice.
Questions for your advisor:
How is my AML/CTF program tailored specifically to my venue's operations and risk profile?
Does your development process include site visits or detailed operational inquiry?
To what extent do you rely on templates versus customised analysis?
2. Risk Assessment Methodology: Evidence-Based Analysis
What AUSTRAC has found: Cases where all risks were uniformly labelled "low" without supporting justification or data analysis.
Questions for your advisor:
What methodology underpins your risk assessment process?
How do you incorporate both quantitative data (EGM numbers, turnover, loyalty card usage, customer demographics) and qualitative factors?
Do the identified risks accurately reflect what my business actually faces?
3. Money Laundering Techniques: Real-World Understanding
What AUSTRAC has found: Risk assessments overlooking known money laundering methodologies in gaming venues, including ticket buying and selling schemes, or gambling patterns inconsistent with customer profiles.
Questions for your advisor:
Does your methodology consider known money laundering techniques relevant to gaming venues?
How comprehensive is the range of red flag indicators included in the assessment?
How do you maintain currency with evolving ML/TF risks in the sector?
4. Operational Alignment: Documenting Reality
What AUSTRAC has found: Disconnects between documented AML/CTF programs and actual venue operations, including procedures not followed in practice.
Questions for your advisor:
How do you verify alignment between documented programs and actual policies, procedures and guidelines?
What process do you follow to assess program implementation effectiveness?
How do you evaluate whether controls operate as intended in practice?
5. Program Detail: Meeting Regulatory Requirements
What AUSTRAC has found: Enhanced Customer Due Diligence programs consisting of only one or two paragraphs, failing to meet AML/CTF Act and Rules requirements. Programs using ambiguous language ("may undertake," "could be applied") that makes compliance demonstration difficult.
Questions for your advisor:
What level of detail and specificity does your program provide?
What deliverables and recommendations will the independent review produce?
6. Training Alignment: Venue-Specific Learning
What AUSTRAC has found: Training programs outlining risks inconsistent with venues' own assessments and programs. Reliance on generic training not addressing venue-specific circumstances.
Questions for your advisor:
How is training customised to address our specific risk profile and program requirements?
Does training cover known money laundering methodologies and their potential impact on our operations?
What ongoing implementation support do you provide?
Does training content align with topics outlined in our AML/CTF program?
Understanding the Regulatory Environment
Penalties Under the AML/CTF Act
Breaches can result in criminal penalties, civil penalties, or other disciplinary action:
Maximum civil penalties:
Body corporate: up to $33 million
Individuals: up to $6.6 million
Considerations When Selecting AML/CTF Advisors
Effective advisor selection balances cost considerations with the quality and appropriateness of services. Generic or automated solutions increasingly fall short of regulatory expectations, creating exposure to compliance findings, financial penalties and reputational impact.
What to Look For
Advisors who demonstrate:
· Legislative knowledge - Deep understanding of the AML/CTF Act and Rules
· Tailoring capability - Programs and risk assessments reflecting your venue's specific circumstances rather than standardised templates
· Practical focus - Solutions that can be effectively implemented and support compliance in practice
· Independent rigor - Reviews that are substantive, constructive and enable genuine risk response
While outsourcing to advisors can be effective, certain obligations remain with the reporting entity. Understanding which responsibilities cannot be delegated is essential when structuring your compliance approach.
Common Questions About Gaming Venue AML/CTF Compliance
What triggers AML/CTF reporting requirements?
Venues with entitlements to operate 16 or more gaming machines must comply with AUSTRAC reporting and program requirements.
When is the AUSTRAC Annual Compliance Report due?
Reports must be submitted by end of March 2026 for gaming venues within scope.
Can venues rely on generic industry training?
AUSTRAC requires training tailored to venue-specific risks. Generic programs, including those provided by third parties for other purposes, do not satisfy this requirement.
Who is liable if an advisor provides an inadequate program?
The reporting entity, your venue, remains legally liable for compliance. Enforcement actions and penalties apply to the venue regardless of advisor involvement.
How frequently must independent reviews occur?
Independent reviews of AML/CTF programs and ML/TF risk assessments must be conducted at regular intervals as required under the AML/CTF Act.
Positioning Your Venue for Regulatory Success
The difference between compliance frameworks that withstand scrutiny and those that create exposure often comes down to advisor quality and approach. Investing in tailored, substantive programs demonstrates commitment to managing financial crime risk and protects against regulatory, financial and reputational consequences.
What This Means for Your Business
Template-based approaches increasingly fail to meet AUSTRAC's expectations
Quality of advisor expertise directly impacts compliance outcomes
Proper due diligence in advisor selection reduces regulatory risk
Tailored programs support both compliance and operational effectiveness
Next Considerations
As regulatory expectations continue to evolve, gaming venues benefit from frameworks that are not only compliant but genuinely effective in managing ML/TF risk. This requires advisors who understand both the regulatory environment and the practical realities of venue operations.
Understanding what questions to ask, and what answers to expect, positions your business to navigate the regulatory landscape with confidence.
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. 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.
