AML/CTF

Why you need an AML Program

Clubs with 16 or more EGMs are a ‘Reporting Entity’ under AUSTRAC Rules.

The Anti-Money Laundering/Counter Terrorisim Financing Act 2006 (AML/CTF Act) prohibits a club from allowing people to play a game on a gaming machine unless the club has an AML/CTF program approved by the directors in place.

What is a ‘Reporting Entity’

An entity that provides any designated services listed under section 6 of the AML/CTF Act. These entities generally provide financial, gambling, bullion or digital currency exchange services. All reporting entities must meet obligations under the AML/CTF Act.

Penalties for Non-Compliance

The maximum penalty for a club is $21 million per breach. The maximum penalty for an individual (including directors and senior management of clubs) is $4.2 million per breach. These are significant amounts of money, and directors and officers should be aware that they are not covered by insurance for these types of penalties.

Our Services

Barringtons AML/CTF Services for Clubs include the following:

• Develop an AML/CTF Program for your venue
• Provide an AML/CTF Risk Assessment for your venue
• Facilitate regular independent review of your AML/CTF Program
• Provide advice and assistance in implementing your AML/CTF Program
• Online AML/CTF risk awareness training program for your staff
• Online training program for your designated compliance officer to understand their obligations in this role