Australia’s financial watchdog AUSTRAC has issued key updates to its Regulatory Guide that affect how pubs and clubs manage their AML/CTF obligations.
In October AUSTRAC released its updated Regulatory guide for pubs and clubs with gaming machines, and accompanying priorities, reflecting the forthcoming reforms under the Anti‑Money‑Laundering and Counter‑Terrorism Financing (AML/CTF) Act 2006.
There are multiple elements to the updates, including new sectors such as accounting and real estate to be brought under the Act, from 1 July 2026.
The regulator is homing in on the quality of Suspicious Matter Reports (SMRs) and other transaction data, versus the quantity of SMRs.
Businesses that are already regulated must prepare for upcoming reforms, coming into effect 31 March 2026, including revised program requirements and enhanced reporting obligations, with a stronger emphasis on risk-based outcomes.
“The regulator is making clear that merely ticking boxes won’t suffice,” advises Christo Nurtsis, from compliance software PaySafeGo.
“AUSTRAC expects businesses to adopt proportional, outcome-oriented AML/CTF programs rooted in actual money-laundering, terrorism-financing or proliferation-financing risks (ML/TF/PF).”
These updates differ from the previous guide primarily in shifting from guidance emphasising foundational compliance under the existing Act, focusing on operators having a program, toward asking if the program is effective and if it reflects actual risk.
While obligations for many current entities were previously stable, the major reform cites clear instruction and legal requirement on what entities MUST HAVE rather than SHOULD DO.
Risk definition and expectations are highlighted, and venues must be aware of all even when simple changes occur and keep risk assessments updated and documented.
While earlier guides focused largely on compliance with the Act and the rules ‘as they stand’ the updated version emphasises the need to be ‘forward-looking’ on activity and responsibilities. It outlines how the Board and senior execs are ultimately responsible for assessing risks and establishing monitoring compliance.
Transaction monitoring is expected even in uncarded play. Venues should anticipate exception reporting and independent audits, and the ease with which venues provide information will be considered.
HOW WILL THIS AFFECT YOU
The new guidelines represent an investment in ‘future-proofing’ and preparation will be key, with reforms coming into effect in March and July 2026.
Operators need to translate risk assessment into actionable compliance, and produce guidance for all staff to help them keep within the rules.
The quality of reporting and data is increasingly important to AUSTRAC.
Tools such as PaySafeGo aim to ensure transaction flows, audit trails and documentation are captured in structured, compliant formats, which helps avoid further regulatory scrutiny. The company also proactively reviews AUSTRAC updates and provides venues with tailored guidance and support – in plain language – to interpret changes in obligations.
“The new AUSTRAC guidance demands more than a static compliance checklist,” adds Nurtsis.
“Paysafego’s platform and services help you embed AML/CTF controls that are automated and align to real business risk.”
Venues with gaming are advised to review their current AML/CTF program against the updated AUSTRAC expectations and stay informed on further guidance.
Ensure the venue has a documented plan, particularly a risk assessment, and consider how processes for onboarding, monitoring and reporting may need to evolve in light of the reforms.
Best practise may be to engage a consultant or independent auditor to review existing processes and map out a plan.
“As a provider of payment and value transfer services, gaming venues are operating in a high-risk environment where regulatory expectations are evolving quickly,” concludes Nurtsis.
