AUSTRAC at AGE: Clarity, Not Surprises

TL;DR

• AUSTRAC’s enforcement against Mounties is a signal, not a surprise - more clubs and pub groups are expected to follow.
• Litigation will drag into 2026, but the operational and reputational impacts are immediate.
• AUSTRAC has been warning pubs and clubs for years: cookie-cutter AML/CTF programs aren’t enough.
• Boards must show active oversight, compliance resourcing needs to match business scale, and programs must be venue-specific and evidence-based.
• With legislative simplification and new guidance due by March 2026, now is the time to reset and prove your compliance.

AUSTRAC at AGE: Clarity, Not Surprises

At this year’s Australasian Gaming Expo (AGE) in Sydney, I attended a panel discussion where experts - including Addisons lawyers Jamie Nettleton and Lachlan Gepp, Michael Simone of Bankstown Sports Club, Brad Brown from AUSTRAC, and Frank Makryllos of Ebet - provided valuable context around AUSTRAC’s enforcement action against Mounties Group.

The conversation made one thing clear: while the Mounties case is still unfolding, the regulator’s expectations for pubs and clubs are now crystal clear.

Litigation: What to Expect

The panel noted that AUSTRAC litigation is rarely quick. A more detailed statement of claim is expected in the coming months, followed by negotiation and mediation that could stretch well into 2026.

Most AUSTRAC cases settle, typically with significant fines approved by the Federal Court. While a full trial on liability would be unusual, the consensus was that a negotiated penalty is the likely outcome.

For other venues, the real lesson is that the process itself carries weight: once AUSTRAC takes action, the operational and reputational impact is immediate, regardless of how long the legal matter takes to resolve.

Why AUSTRAC Acted

The regulator’s move against Mounties wasn’t sudden. Over the past several years, AUSTRAC has:

• Run a national engagement campaign with over 800 venues.
• Released a dedicated pubs & clubs regulatory guide - a first for any Australian industry.
• Consistently warned that “cookie-cutter” AML/CTF programs are not enough.

The Mounties filing reflects those themes: AUSTRAC has highlighted specific program deficiencies and made clear that generic approaches don’t meet the standard.

Lessons for Venues

The panel shared several takeaways that go beyond one case:

• Scale your compliance to your business: headcount, resourcing, and systems need to be proportionate to gaming turnover and payout volumes.
• Board accountability: Directors must actively engage with AML/CTF oversight, not just delegate.
• Evidence, don’t assume: venues need documented monitoring logic, thresholds, and procedures that can be demonstrated to regulators.
• Location matters: operating near borders or in high-crime areas changes your risk profile.
• Culture counts: compliance can’t be an afterthought; it has to be part of daily operations.

Looking Ahead

The sentiment from the panel is that Mounties won’t be the only case. We can expect a handful of further enforcement actions across both large clubs and pub groups over the next 18–24 months. AUSTRAC is likely to focus on well-known operators to reinforce its message across the sector.

At the same time, legislative changes and new guidance materials are on the horizon, with simplification measures due by March 2026. For venues willing to act now, the path forward is clearer than it has ever been.

A Constructive Way Forward

AUSTRAC takes into account the cost of compliance when shaping its guidance. What it doesn’t do is weigh compliance cost against a venue’s profit. The expectation is simple: that businesses make reasonable, proportionate investment in compliance and can demonstrate that their systems are working.

For venues, that means:

• Revisiting AML/CTF risk assessments.
• Ensuring monitoring programs are specific and effective.
• Building a compliance culture that extends to the Board.

The good news is that there are advisors (👋🏻 Hello!), resources, and purpose-built tools available to help. The industry doesn’t need to start from scratch.

Involv’s Perspective

At Involv, our role is to translate this clarity into practical action. We work with venues to:

• Reset AML/CTF programs so they reflect venue-specific risks.
• Design monitoring rules that work in practice, not just on paper.
• Support Boards with clear reporting on inherent and residual risk.
• Deploy technology like Sentinel and Assure, which are purpose-built for Australian pubs and clubs.

The AGE discussion showed that AUSTRAC’s expectations are not a mystery. For venues, the challenge now is about implementation and proof. And the best time to start is before the regulator is asking the questions directly.