AUSTRAC Compliance Report: What You Need to Know

Note: Reporting obligations may vary depending on how many gaming machines a club has.

For clubs with up to 15 gaming machines

Clubs licensed to operate up to 15 gaming machines are only required to confirm their enrolment details are current and report the total number of machines they are authorised to operate. 

Clubs with 16 or more gaming machines

Clubs licensed to operate 16 or more machines must complete a full compliance report. 

Further information can be found on AUSTRAC’s Compliance Report webpage or you can preview the 2023 Compliance Report Questions here. You can also review information on how to update your details with AUSTRAC here.

By completing the report, you may identify gaps with either your program’s contents or how your club is complying with the program. This is a good opportunity to develop a remediation plan to improve your AML/CTF compliance practices. 

1. Prepare a remediation plan

Preparing a remediation plan will demonstrate to both your board and AUSTRAC that you are acting to improve the club’s compliance with the AML/CTF Act. 

Depending on any gaps identified, you may require a change to your program and/or the practices in place. For example, your program may address your club's ML/TF risks, however, its implementation is not as effective as it should be. 

Alternatively, your ML/TF risks may have changed, or new information may have been made available on how best to comply with the AML/CTF Act. In these circumstances, both your program and practice may need to be amended. 

2. Be clear on the AML/CTF requirements

It is important to be clear on what the AML/CTF requirements are, what your club is doing to comply with them and the gap between the two. From here, determine what changes are required to comply with your AML/CTF obligations. Remediation could include increasing resourcing/delegation, amending your program, utilising technology to support compliance or engaging consultants and providers.

3. Increasing resourcing or delegation

The Compliance Officer is responsible for the completion of certain tasks though, depending on the size and complexity of your organisation, they may delegate certain responsibilities to colleagues equipped and skilled to complete that task. 

Some examples include employee due diligence being undertaken by the person responsible for human resources; transaction monitoring by gaming analysts or finance teams; and customer due diligence by membership or customer functions.

As your business grows, you may also require more staff to comply with your program and AML/CTF obligations. Consider carefully where the club's resourcing strengths and weaknesses exist and manage resources to bridge any gap.

4. Amending your AML/CTF program

If your program’s implementation is well executed but the program itself is deficient, your club may still be non-compliant. It is important to determine whether gaps are due to an insufficient program, or only insufficient implementation of your program.

Program deficiencies may be a result of improper risk assessment. A full and thorough risk assessment is required to determine what changes are required to a whole program, other times simply changing certain parts of your AML/CTF program may be sufficient. More information is available on AUSTRAC’s AML/CTF Program webpage.

5. Utilising technologies 

Several technology platforms can assist you in managing and streamlining your AML/CTF compliance processes. For example, using customer due diligence (CDD) platforms to conduct preliminary background checks on customers or transaction monitoring systems to identify the potential suspicious flow of money through a gaming room.

Both these types of systems can support clubs by automating and simplifying CDD and transaction monitoring obligations saving countless hours of research and analytics.

6. Leveraging providers or consultants

Using providers and consultants such as an AML/CTF program provider to develop your program or trainers to provide training for boards and staff can be an effective way to minimise compliance costs. An independent review must be completed by someone completely uninvolved in the development and implementation of your AML/CTF program. External providers can assist you with conducting an independent review.

ClubsNSW partners provide a range of AML/CTF services — take a look at the ClubsNSW Business Directory.

7. Provide your compliance report and remediation plan to your board

To ensure they have oversight, the board must receive a summary of your club’s performance against the 2023 Compliance Report questionnaire, with the full report as an appendix. The board should also review and approve any remediation plan.

ClubSAFE

ClubsNSW supports member clubs by advising how to improve AML/CTF compliance should any gaps be identified. The ClubSAFE program also provides a range of services and products such as training, AML/CTF program management, and platforms to support members meet and exceed their AML/CTF compliance obligations. Find out how the ClubSAFE program helps members with their AML/CTF, licensing, and responsible gambling obligations here.

If you have any questions, please contact the ClubASSIST team at [email protected] or by calling 1300 730 001.