AUSTRAC Commends Clubs Australia for Its Role in Achieving Record-High Reporting Standards

As part of the conference, AUSTRAC CEO Brendan Thomas spoke about the important role clubs play in protecting their communities and maintaining trust in gaming. 

He recognised the positive and constructive relationship between AUSTRAC and Clubs Australia, noting that clubs are increasingly confident in raising concerns and working collaboratively with regulators. 

He also acknowledged strong progress by clubs in identifying and reporting suspicious activity, describing this as a sign of a maturing compliance culture.

Key Insights From AUSTRAC and Industry Experts

Speakers highlighted that money laundering is not always obvious. It can involve everyday appearing behaviour such as:

• Inserting cash into gaming machines and cashing out with minimal play (“bill stuffing”).
• Using multiple identities.
• Misusing vouchers or prepaid cards.

These risks can exist in any cash-based environment, including clubs.

AUSTRAC Insights

AUSTRAC expressed positive sentiment toward the club industry, recognising its genuine commitment to AML/CTF compliance. In response to questions, Brendan Thomas noted that AUSTRAC is:

• Exploring how to provide assurances for regulatory technology services and providers.
• Developing regulation to support information sharing between reporting entities.
• Providing clearer guidance on what good suspicious matter reports (SMRs) look like.
• Launching a new AUSTRAC compliance tool this month to support clubs.

Expert Insights: Common Pitfalls and Practical Advice for Clubs 

Clubs aiming to strengthen compliance should be aware of several common pitfalls and focus on practical improvements:

• Don’t rely on “cookie-cutter” policies; tailor policies to your specific risks and regularly review them.
• Balance manual checks and automation; manual processes may miss patterns, while automation can overlook context. Regularly review both to identify gaps.
• Define clear compliance roles and encourage teamwork. Avoid situations where compliance and gaming teams each assume the other is in charge. Set clear responsibilities and encourage collaboration.
• Critical thinking is essential throughout the organisation. Policies should encourage staff to analyse their use and impact, rather than just exist on paper.
• Effective compliance is not just about having policies in place, but about regularly reviewing whether systems work in practice and whether they genuinely reduce risk. Do not assume a policy is effective just because it’s in place.
• Keep compliance and commercial decisions separate. Avoid conflicts where business pressures might undermine compliance outcomes. Make sure compliance staff have the independence they need.
• Make sure compliance issues and risks are clearly reported to your board. Avoid overly technical or vague reports, and focus on what matters and what action is needed.
• Boards are crucial for compliance. Directors must question, gather risk details and support ongoing practice improvements.

By focusing on these practical steps, clubs can build a stronger, more effective compliance culture that protects both the organisation and its community.

Staff Awareness is Critical

Industry case studies show that front‑line staff play a crucial role in identifying and responding to unusual activity. Short, practical training and real‑world examples help staff recognise potential risks and feel supported to escalate concerns appropriately. 

How Clubs Are Responding

Across Australia, clubs are continuing to strengthen their approach by:

• Investing in practical procedures and staff training.
• Encouraging a “see something, say something” culture where staff are supported to report concerns.
• Engaging openly with regulators and learning from guidance and industry forums.
• Improving board oversight so compliance and risk management remain core priorities.

These measures support safer environments for members and staff and help ensure clubs remain trusted community institutions. 

As AUSTRAC has noted, increased reporting across the sector demonstrates that clubs are taking these responsibilities seriously and contributing positively to Australia’s financial integrity. 

A Shared Commitment

AUSTRAC acknowledged the ongoing, proactive collaboration with Clubs Australia to support practical and balanced implementation of the AML/CTF regime. 

Clubs Australia has also discussed developing starter kits for small clubs and meets quarterly with the AUSTRAC CEO to support continuous improvement across the sector.

If you have any questions, contact ClubAssist on 1300 730 001 or [email protected].