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’

A reporting entity provides any designated services listed under section 6 of the AML/CTF Act. These typically include financial, gambling, bullion, or digital currency exchange services. All reporting entities must meet the obligations outlined in the AML/CTF Act.

Non-Compliance carries significant penalties:

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 provides a comprehensive range of AML/CTF services, including:

• Developing an AML/CTF Program tailored to your venue
• Conducting an AML/CTF Risk Assessment to identify and mitigate risks
• Facilitating independent reviews of your AML/CTF program
• Offering practical advice and assistance for implementation
• Online risk awareness training for staff, using realistic scenarios to demonstrate how money laundering and terrorism financing can occur in venue operations
• Compliance Officer training to ensure designated officers understand their obligations, due diligence requirements, and AUSTRAC responsibilities
• AML/CTF Compliance Training for Staff and Compliance Officers