Compliance a Major Focus as Regulator Eyes Improvements

A key takeaway from the session was the need for clubs to move beyond “set-and-forget” approaches to Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF). Instead, AUSTRAC encouraged a shift toward proactive, risk-based compliance practices that are embedded into everyday operations.

In 2025, AUSTRAC has emphasised a robust approach to compliance, governance, and reporting within pubs and clubs. 

The regulator has identified areas needing improvement, particularly concerning Suspicious Matter Reports (SMRs), AML/CTF Programs, and Transaction Monitoring Programs (TMPs). 

This article details AUSTRAC’s regulatory priorities, reforms, sector performance and offers compliance improvement suggestions for clubs.

AUSTRAC’s Regulatory Priorities - What Clubs Need to Know

AUSTRAC’s 2025 priorities focus on compliance, governance and reporting. The regulator noted an uplift in compliance assessments across pubs and clubs but also highlighted persistent gaps, including:

• SMRs remain a weak point, with low submission rates and poor reporting quality. AUSTRAC highlighted that SMRs can—and should—be submitted even when no transaction occurs, such as in cases of suspicious behaviour like hassling gamblers to buy winning tickets but not engaging in gambling.
• AML/CTF Programs should not be in template form; rather, clubs must ensure their programs are venue-specific, with clear procedures that are actively followed.
• TMPs are frequently manual and misaligned with venue risk profiles. An automated process should be used where staff cannot observe transactions directly.
• Governance failures were noted, including ineffective escalation processes and minimal board-level reporting on outsourced AML/CTF functions.
• AUSTRAC reinforced that good reporting reflects a strong underlying compliance framework. Clubs should treat reporting as a showcase of their AML/CTF maturity.

Reforms and Risk - A New Compliance Paradigm

The forum previewed upcoming reforms aimed at simplifying obligations and expanding regulation to tranche 2 entities. These reforms will:

• Formalise risk assessment as the foundation of AML/CTF programs.
• Shift away from tick-box compliance toward outcomes-based accountability.
• Introduce risk-based flexibility.

'It highlights the need to be actively assessing, adjusting and training our team based on the real risks in our venues."  - Stephanie Lenehan, Group Compliance Manager, Cabra-Vale Diggers 

Importantly, AUSTRAC acknowledged that a three-year risk assessment cycle may not suit all venues. Frequency should be determined by the venue’s risk profile, which must be actively identified and updated.

Intelligence and Compliance Report 2024: Sector Performance

AUSTRAC’s 2024 reporting cycle revealed:

• Only 8 per cent of venues conducted ML/TF assessments in response to AUSTRAC guidance—a missed opportunity to strengthen compliance.
• Additionally, only 24 per cent of venues obtained senior management approval for designated services under Enhanced CDD and just 28 per cent did so for continuing high-risk customer relationships.

Member Webinar Series

ClubsNSW is launching a dedicated AML/CTF Compliance Webinar Series aimed at helping member clubs simplify and strengthen their compliance frameworks. 

Members can subscribe here to be notified as the series is released, as well as submit their questions, challenges or suggestions for topics of discussion in advance. 

Moving Forward

Clubs should take stock of their AML/CTF frameworks and ask:

• Are our programs tailored and actively implemented?
• Do we have automated monitoring where needed?
• Are our governance and escalation processes documented and effective?
• Are we training staff to identify and report suspicious activity?

AUSTRAC’s message is clear: compliance is not optional, and clubs must demonstrate a genuine commitment to risk management and regulatory engagement.

The webinar recording will be uploaded to AUSTRAC’s YouTube page, available here.  If you have any questions, please contact ClubASSIST on 1300 730 001 or [email protected].