Recent activity by AUSTRAC (Australia’s financial intelligence agency, governing anti-money laundering and counter-terrorism financing) is believed to be part of plans for increased reporting by hospitality operators, says consultant firm Risk Training Australia.


Phillippa Lloyd

Submitted by Phillippa Lloyd, Risk Training Australia

AUSTRAC recently published a notice advising all pubs and clubs they do not have to complete the AUSTRAC online return for their venue this year.

This publication shows that AUSTRAC are turning their attention to pubs and clubs, and moving away from the current approach. In our opinion, this means they will have a more stringent method of reporting.

The AUSTRAC publication states:

“Rather than be seen as simply ‘ticking a box’, we aim to make this yearly exercise genuinely useful for reporting entities and AUSTRAC alike. We anticipate the co-designing process will result in a new report that better meets the needs of both industry and the regulator. 

“I assure you that AUSTRAC is not weakening its regulatory oversight while this process is underway. A range of compliance activity will continue throughout this period.”

There were a large number of audits this year. Following the additional attention that AUSTRAC is going to give the hospitability industry, as well as the development of compliance and regulations over the next 12 months, we believe it is a strong possibility AUSTRAC reporting will become stricter, and that audits by AUSTRAC will increase. AUSTRAC could review your venue at any given time.

We therefore recommend you continue to conduct business as usual and follow all the processes and procedures you currently have in place.

It is an AUSTRAC requirement* that all pubs and clubs have an up-to-date Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program, and follow a diverse range of obligations set by AUSTRAC. This continues to remain an obligation for all gaming venues.

Fines of non-compliance: up to $11 million for companies, $2.2 million for individuals

Gaming venues must ensure they have the following procedures in place to comply with legislation to avoid the severe penalties (as per AML/CTF Act 2006 and the AML/CTF Rules 2007):

  • Implement and maintain an up-to-date AML/CTF compliance program
  • Appoint a trained and knowledgeable AML/CTF compliance officer
  • Conduct staff training on AML/CTF and ensure a training register is maintained along with current staff certificates of completion
  • Conduct annual reviews on AML/CTF to ensure all processes and procedures are being adhered to


For help with compliance, contact RCA Group – parent company to Risk Training Australia


*Anti-Money Laundering / Counter-Terrorism Financing Act 2006

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