Gaming machine money laundering: What do operators need to do to comply with AML/CTF Laws

Gaming machine money laundering: What do operators need to do to comply with AML/CTF Laws


Poker machine money laundering is in the spotlight again after concerns around serious and organised criminals targeting pubs and clubs to launder money.

With the news regarding SkyCity, AUSTRAC has cited ‘systemic failures’ in the operator’s anti-money laundering and counter-terrorism financing (AML/CTF) programs, particularly regarding the failure to have a transaction monitoring program and to carry out appropriate ongoing customer due diligence, including on some very high-risk customers.

Australia’s thriving pub and club industry is not exempt from scrutiny. Electronic gaming machine operators, including pubs and clubs with electronic gaming machines (EGMs) are required to actively mitigate and manage their money laundering and terrorism financing (ML/TF) risks. Business with entitlement to operate 15 or less EGMs may be exempt from some obligations, however they must still enrol with AUSTRAC and report suspicious matters.

AML/CTF requirements for gaming machines operators

Pubs and clubs with EGMs should ensure they have/do the following:

  • Complete a risk assessment to identify money laundering and terrorism financing risks your business faces and tailor your AML/CTF program to the business.
  • Collect and verify ‘know you customer’ (KYC) information.
  • Have a transaction monitoring program.
  • Have ongoing customer due diligence and carry out additional checks on higher risk or suspicious customers.
  • Report suspicious matters to AUSTRAC e.g. if you suspect a person is linked to crime or a customer is not who they claim to be. Low reporting compared to peers may indicated an ineffective AML/CTF program.
  • Do not tell customers that you have reported them in a suspicious matter report (SMR).
  • Maintain accurate records of transactions e.g. a cheque register of payouts.
  • Have processes so that staff working on the gaming floor can help to identify and report suspicious behaviour.
  • Have an employee due diligence program.
  • Submit annual compliance reports to AUSTRAC.
  • Notify AUSTRAC of any changes such as a new compliance officer or updated contact information.
  • Undertake regular independent reviews of Part A of your AML/CTF program.

How can SW help?

Our highly experienced team works closely with organisations across multiple industries, including the tourism and hospitality sectors, to ensure their AML/CTF programs are compliant  and appropriate to the needs of the business. We can review your current programs and processes, advise where the gaps are, or review your  compliance with AML/CTF requirements.

Reach out to our experts for an obligation free discussion about your current program, details about how we can help with a review of your AML/CTF program and provide tailored recommendations.


Jonathan Thomas and Laura Toscano

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