AML Scrutiny Expected to Intensify for Clubs and Gaming Venues
Australia’s financial crime regulator is shifting its enforcement focus toward clubs and venues with electronic gaming machines. With expectations of increased scrutiny, venues should prepare now by reviewing their AML/CTF frameworks, risk assessments, and customer due diligence processes. Those who wait may find themselves playing catch-up under regulatory pressure.
Louise Lane
12 March 2025
2 min read
Over the past year, Australia’s financial crime regulator has signalled a shift in its enforcement priorities - one that should have the attention of clubs and venues operating electronic gaming machines (EGMs). With recent enforcement waves targeting casinos and online betting operators, it's becoming clear that pubs and clubs may be next in line.
Venues in jurisdictions like New South Wales, Victoria, and Queensland - especially those with extensive gaming floors or sporting affiliations - could soon be under the compliance microscope.
Why the Focus Is Shifting
The broader regulatory trend is moving toward sectors perceived to have significant exposure to cash-based transactions and large customer volumes, particularly in environments where ongoing customer due diligence can be complex. Pubs and clubs with EGMs fit this profile and are often underpinned by legacy systems, variable training levels, and inconsistent implementation of anti-money laundering (AML) controls.
What Regulators Are Looking For
Venues should expect attention on:
- The design and effectiveness of their AML/CTF Programs
- Risk assessments that reflect the scale and nature of gaming activity
- Active board and senior management oversight
- How customer due diligence is performed and documented
- Detection and reporting of suspicious transactions or activity
What Comes First
Regulatory engagement often begins with a “landscape review”—a period of data collection where the regulator seeks to understand how compliance obligations are being met across the sector. This may involve formal information requests to venues, seeking policies, transaction data, and records of internal oversight.
This is not a superficial scan. Highly resourced operators in other industries have faced findings of significant non-compliance, underscoring that complexity, not intent, is often where vulnerabilities lie.
What Venues Should Be Doing Now
Venue operators would be well advised not to wait for contact. A proactive internal review of AML/CTF controls - especially those related to EGM operations - can uncover gaps before a regulator does. That includes checking the alignment between risk assessments, procedures, training, and actual frontline execution.
As scrutiny builds, the venues that fare best will be those that can demonstrate a genuine culture of compliance, not just a checklist approach.