AML/CTF is now a standing obligation, not a project
The reformed AML/CTF framework commenced for existing reporting entities on 31 March 2026, with a range of transitional provisions applying to certain obligations. Five changes matter most on a club floor:
- Identification moves from photocopying to sight-and-record – sight the original, record the prescribed details, return the document. Procedures, staff training and legacy ID archives all need attention.
- Compliance officer. Reporting entities should ensure a suitably qualified AML/CTF Compliance Officer has been appointed and notified to AUSTRAC in accordance with applicable transitional requirements.
- Transaction monitoring must now detect amount clustering, velocity spikes and split payouts — patterns that run across shifts, machines and days, and cannot be caught by observation alone.
- Program tailoring. Generic AML/CTF programs that have not been appropriately tailored to the venue’s risk profile are unlikely to satisfy AUSTRAC expectations.
- Refresher training must cover sight-and-record, the new structuring indicators, escalation to the compliance officer and tipping-off provisions, with attendance records retained.
Maximum civil penalties for corporate contraventions are now $33 million. The practical test in an audit is rarely the document; it is whether you can evidence who was trained, on what, and when.
BARRINGTON DIARY
| 15 SEP 2026 | Liquor & Gaming webinar on ID verification | NSW |
| BEFORE YEAR END | ACT Government response to the Kimmitt inquiry expected | ACT |
| ONGOING | AML/CTF refresher training delivered and attendance records retained | ALL |
| 2028 | Statewide exclusion register live; mandatory facial recognition at gaming room entries | NSW |
| ONGOING | Development of infrastructure supporting future account-based gaming | NSW |
| 2045 | Proposed end point of the ACT transition — 1,000 gaming machines | ACT |
| THIS MONTH’S PROGRAM
Tier 1 Mandatory Compliance GOVERNANCE · FINANCE FOR BOARDS Two one-day programs built for registered club directors, delivered by Barrington Training Services. Between them they cover BSBOPS406 and BSBFIN501 — the two units the Registered Clubs Regulation 2025 names as the approved-RTO pathway for mandatory NSW director training. Both units are on our scope of registration. FORMAT One day each, in person or virtual classroom WHO IT’S FOR Club directors — newly appointed and returning board members INCLUDED Responsible Gambling Board Oversight (1 hour) with Tier 1 program days ON COMPLETION A nationally accredited statement of attainment LCA MEMBERS Leagues Club Australia member clubs receive a member discount Request dates and pricing from your Barringtons Contact |
Let Barringtons help you get your compliance in check. Enquire now!
