Regulatory Update | AUSTRAC Enforcement Priorities

AUSTRAC expected to turn its enforcement attention to Clubs and Venues with EGMs

The new AUSTRAC CEO, Brendan Thomas, has refreshed his leadership team and is making AUSTRAC’s enforcement intentions in respect of clubs and venues with poker machines very clear. A recent interview which Mr Thomas gave to the AFR can be accessed here.

Against that background, AUSTRAC will almost certainly focus on the clubs and venues sector as part of its next “job lot” having dealt with the casinos and online wagering companies. We would expect this focus to start with those clubs and other gaming venues in NSW, Victoria and Queensland that have the largest gaming offerings and there may be a particular interest in organisations that are partnered with AFL/NRL clubs and racing clubs.

Key areas of attention are likely to be the compliance and appropriateness of an organisation’s AML/CTF program and underlying money laundering/terrorism financing risk assessment, board/senior management oversight, ongoing customer due diligence and unusual or suspicious matter reporting.

Next Steps

AUSTRAC’s first step with a new sector is typically a fact gathering exercise to understand the compliance landscape of the relevant reporting entities and to identify any threshold concerns. This would take the form of statutory notices issued to clubs and venues seeking information and documents.

As demonstrated by AUSTRAC’s enforcement action in other sectors, the obligations under the AML/CTF Act and Rules are onerous and even the most sophisticated entities have been found to have areas for improvement.

We will monitor AUSTRAC’s activity in the clubs and venues sector and provide further updates as things develop.

Please contact a member of the Addisons Gambling Team for further information or support in respect of AUSTRAC or AML/CTF compliance.

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