Transaction Monitoring of Gaming Rooms: Some Considerations

As a pub or a club with gaming machines, multi-gaming terminals, cash redemption/ticket redemption terminals, and cashiers, you are required to have a transaction monitoring program in place that will enable you to detect:

Unusual transactions or patterns of transactions;
Structuring (breaking large transactions into smaller ones to avoid reporting thresholds);
Transactions with people in high-risk countries, or with people on a sanctions or politically exposed person (PEP) list; and
Unusual customer behaviour that may indicate money laundering or terrorism financing.

AUSTRAC makes this clear in its guidance materials available here: Transaction monitoring | AUSTRAC

(…it is recommended that reporting entities have AUSTRAC’s website as a ‘favourite’ to make sure you’re up to date on their guidance materials!)

START WITH THE RISK ASSESSMENT

As ‘reporting entities’ under Australia’s AML laws, pubs and clubs with gaming machines will have in place AML/CTF Programs that describe their process for assessing the ML/TF risks faced by the business, having regard to the nature, size, and complexity of the business.

Known as the “Enterprise-wide ML/TF Risk Assessment,” or your “EWRA,” it should consider:

Customer Risk: Who are your patrons and what risks do they present
Product Risk: Which services are most vulnerable to misuse?
Channel Risk: How do customers interact with your gaming facilities
Jurisdiction Risk: Are there geographic risk factors (i.e., do you deal with foreign jurisdictions)?
Employee Risk: How might staff be involved?
Location Risk: Does your venue’s specific location create its own risks
Threat Environment: What current criminal methods are targeting venues like yours?

You should also have a clear assessment of the red flags or typologies that are common for the pubs and clubs industry. There are several useful guides that can help, including:

These are not exhaustive and should supplement your findings in your EWRA.

If your AML/CTF Program or EWRA is outdated or hasn’t been reviewed in the last 12 months, get in touch with us.

KNOW YOUR TRANSACTION AND CUSTOMER DATA AND SYSTEMS

Once you understand the nature of suspicious activity, assess:

What data might indicate ML/TF activity?
What data do you have access to, and how reliable is it?
When and how is the data available (real time, delayed)?
Does the data need cleaning or transformation to be useful?

Also map out the entry, flow, and exit points of potential illicit funds (e.g., cash into gaming machines), and identify which departments or staff are best placed to observe these activities.

Remember: Poor quality or incomplete data leads to poor outcomes—get this foundation right.

ESTABLISH CLEAR TRANSACTION MONITORING RULES

For each monitoring activity, ask:

Why am I reviewing this data?
What specific suspicious activity am I looking for? Which risk factor does it sit under and/or which typology is this picking up?
What makes a transaction unusual for our venue (or for this particular customer)?
Am I combining multiple data sources? If so, how and why?

Clear rules help:

Create consistency (across staff and venues);
Allow appropriate resource allocation;
Help management understand and approve the monitoring approach; and
Prepare for technology solutions.

DATA + RULES = OPPORTUNITY FOR TECH ENHANCEMENT

If you’re still using spreadsheets, consider whether that’s sustainable. Tech-based monitoring systems can:

Automate data collection
Apply consistent rules
Reduce false positives
Detect related activity across machines and visits
Create internal and regulatory reports
Visualise patterns via dashboards
Scale with transaction volume

Look for systems that are purpose-built for gaming venues (not generic AML tools), can integrate with your gaming software, and offer strong privacy and flexible rule configuration.

HOW DOES TRANSACTION MONITORING FEED YOUR RISK ASSESSMENT?

Transaction monitoring isn’t one-way - it should improve your risk assessment:

Are alerts aligned with known risks?
Are alerts genuine or false positives?
Are risks increasing in some areas?
Are some venues riskier than others?
Are controls keeping pace with risk changes?

Keep documentation of how your monitoring program informs ongoing risk management.

CONCLUSION

Transaction monitoring is not just about compliance—it protects your venue. A structured, tech-ready monitoring program:

Aligns with your unique risk profile
Uses your data effectively
Evolves as threats change
Lays the groundwork for smarter tech adoption

Pubs and clubs that take this seriously reduce risk exposure, avoid regulatory penalties, and help maintain the integrity of Australia’s financial system.

Need help designing or reviewing your transaction monitoring setup? Contact Involv today to arrange a consultation.