AUSTRAC’s Regulatory Focus on Pubs and Clubs
AUSTRAC has reaffirmed its focus on the gambling sector, including pubs and clubs, in its Regulatory Priorities 2024. Recent compliance assessments highlight key areas of concern, emphasizing that Australia’s AML/CTF regime is risk-based, meaning systems and controls must reflect a venue’s specific size and exposure to money laundering (ML) and terrorism financing (TF) risks.Key observations include:
- Tailored ML/TF Risk Assessments: Templates alone are insufficient; assessments must reflect the venue's unique risks, backed by qualitative and quantitative data.
- Operational Relevance: AML/CTF programs must align with the venue’s actual practices and provide sufficient detail to be actionable by staff.
- Risk Awareness Training: Training must address the venue’s specific ML/TF risks and cannot rely solely on generic programs from third parties.
- Independent Reviews: Reviews must go beyond “tick-a-box” exercises, thoroughly assessing program compliance and effectiveness.