UncategorizedSeptember 21, 2026by Mariana Paul Gerard0Club Compliance: What’s Changing and What’s Next

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!

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