AML/CTF penalties offer critical lessons for community clubs
21/08/2025
The regulator AUSTRAC has launched civil penalty proceedings against an NSW community club for serious and systemic non-compliance with Australia’s Anti-Money Laundering and Counter-terrorism Financing (AML/CTF) requirements.
Weaknesses of the AML/CTF program:
- Failed to set out clear methods to identify, mitigate, or manage the Money Laundering and Terrorism Financing (ML/TF) risks the club could reasonably faced.
- Did not keep a record of all staff who had completed AML/CTF training, including initial and refresher training dates of completion.
- Failure to apply appropriate enhanced customer due diligence.
- Failure to monitor suspicious customers to identify, mitigate, and manage the ML/TF risk they pose.
- Not conducting an appropriate source of wealth or funds check in relation to suspicious customers.
Each contravention attracts a maximum civil penalty between $21m and $31.3m.
Key learnings include:
- Ensure that you have an AML/CTF program that complies with the AML/CTF requirements.
- Include appropriate risk-based systems and controls to monitor the transactions of customers and clearly identify which staff are responsible.
- Have clear processes for when Enhanced Customers Due Diligence should be applied.
- Ensure AML/CTF training meets the requirements of the rules and comply with record-keeping requirements.
- Relying on a third-party provider to manage aspects of your AML/CTF program does not absolve you from your responsibilities to manage your AML/CTF obligations.
How SW can help
SW will continue to monitor developments in AML/CTF compliance and share insights as they arise.
Reach out to your SW contact or our specialist advisers for guidance on how these learnings may impact your club
