Australia's AML/CTF enforcement landscape continues to evolve. Alongside the landmark penalties of the past decade, 2026 has brought a wave of new and ongoing matters across casinos, online wagering and, for the first time, the club sector.

Author: Alexandra Hoskins, Principal

Our earlier overview covered Australia's largest AML/CTF penalties against Westpac, CBA, Crown, SkyCity and Tabcorp. Since then, AUSTRAC has brought proceedings in new sectors, opened fresh investigations and used enforceable undertakings to drive remediation. Below are the key matters shaping the landscape in 2026.

1. Star Entertainment Group (penalty pending)

AUSTRAC commenced its case in November 2022, alleging serious and systemic non-compliance with AML/CTF laws. AUSTRAC argued for a penalty of around $400 million. Star argued that a penalty of that size would force it into insolvency and should not exceed $100 million. In related ASIC proceedings, the Federal Court fined and disqualified Star's former CEO and former Chief Legal and Risk Officer.

Key Issues:

• Management of junket-related risks and escalation of red flags to the Board.

• Personal accountability for senior executives.

2. Entain (hearing listed for November 2026)

AUSTRAC has described this as its first civil penalty proceeding against an online betting business. The allegations concern deficient customer verification, inadequate source-of-funds checks, and cash-deposit and third-party channels. The hearing is set to begin on 30 November 2026, although mediation remains possible.

Key Issues:

• Knowing your customer when deposits come through third parties.

• Board and senior management oversight of the AML/CTF program.

3. Mounties (first proceedings against a club group)

In July 2025, AUSTRAC applied for civil penalty orders against Mount Pritchard and District Community Club Ltd, which AUSTRAC says operates around 1,400 poker machines across eight venues. AUSTRAC alleges the club's risk tables listed risks and responses without explaining how they were identified, rated or managed.

Key Issues:

• A program must operate in practice, not just exist on paper.

• Pubs, clubs and hotels are within AUSTRAC's enforcement focus.

4. Tabcorp (new enforcement investigation)

In May 2026, AUSTRAC commenced an enforcement investigation into Tabcorp, citing serious concerns about its ability to identify, mitigate and manage ML/TF risks. The investigation is at an early stage and all outcomes remain open.

Key Issues:

• Compliance with the AML/CTF Program and adequacy of customer monitoring.

5. Sportsbet and bet365 (enforceable undertakings)

AUSTRAC finalised Sportsbet's enforceable undertaking in July 2026, after an external auditor confirmed the required remediation had been implemented. Days later, bet365 entered its own undertaking after AUSTRAC identified gaps in its risk management and suspicious matter reporting.

Key Issues:

• Early, well-resourced remediation can shape the enforcement outcome.

Key Takeaways for Business

With AML/CTF reforms in effect from 31 March 2026, businesses providing designated services should focus on:

• A Program That Works in Practice: Risk assessments should show how risks are identified, rated and managed.

• Know Your Customer Across Every Channel: Third-party payments, cash deposits and multiple accounts all require attention.

• Active Governance: Boards and senior management must oversee AML/CTF compliance, and accountability can extend to individuals.

• Regular Independent Reviews: Independent assurance identifies gaps early and supports credible remediation.

Would your venue's AML/CTF program, and the advisor behind it, stand up to the kind of scrutiny these enforcement matters show?

Join Alexandra Hoskins for a free webinar: AML/CTF Compliance for Australian Gaming Venues: Conducting an Independent Evaluation and Selecting an Advisor.

With enforcement expanding across wagering, casinos and licensed venues, choosing the right advisor matters. Alex will share what to look for in an AML/CTF advisor, the questions to ask, and how to make sure your program holds up to regulatory scrutiny.

12pm AEDT Wednesday 14th October | Online

Register here.

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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