Reforming Australia’s AML/CTF Regime

In 2023, the Australian Government announced it would be reforming the AML/CTF regime to:

• Ensure Australia remains compliant with the international standards set by the Financial Action Task Force (FATF), the global financial crime watchdog.
• Improve the regime’s effectiveness. 
• Reduce the regulatory burden by simplifying and clarifying the regime, making it easier for businesses, including clubs, to meet their obligations. 

ClubsNSW, through Clubs Australia, provided a submission in response to the first round of consultation last year. Clubs Australia recommended lowering the customer due diligence (CDD) exemption threshold to $5000 (instead of the proposed $4000). 

In April 2024, the Attorney General’s Department announced the second round of consultation regarding the AML/CTF reforms. Our feedback has been considered, and the department is now proposing to reduce the CDD exemption threshold to $5000.  

What are the changes?

The Australian Government is proposing changes to the AML/CTF program, customer due diligence framework and tipping-off provisions, among other reforms. 

To view a comparison of current vs proposed obligations, please click here.

What did our submission include?

Clubs Australia supports the Australian Government’s commitment to implement further measures to safeguard businesses from money laundering activity. To achieve this, a streamlined and clear legislative framework is essential. 

In summary, Clubs Australia’s response:

1. Recommends consideration be given to the impacts on clubs and their diverse array of operating models.
2. Supports lowering the customer due diligence (CDD) exemption threshold for transactions below $5000. 
3. Seeks to ensure that the CDD exemption threshold applies to the assignment of a risk rating. 
4. Recommends that AUSTRAC work with Clubs Australia in developing additional detailed guidance to assist clubs in fulfilling their obligations. 
5. Recommends a fair and proportionate implementation timeline that considers the impact on clubs, especially smaller venues. 

To read our submission, please click here.

What consultation did ClubsNSW undertake?

Consultation is an important part of the policy-making process. Engaging with clubs provides practical insights that inform our response. 

We reached out to various clubs from metropolitan and regional areas, the State Council and the Gaming Advisory Committee, as well as feedback from other Clubs Australia members.  ClubsNSW also sought feedback from members through various circulars. 

We appreciate any comments provided by clubs. 

What happens next?

The Attorney General’s Department will consider feedback from stakeholders before finalising the proposed reforms. We anticipate legislation will be introduced this year. 

The Federal Budget allocated $168 million to support the implementation of these changes. A significant portion of this funding will be used to educate clubs on the new requirements (once legislated). 

We will continue to keep clubs informed of any updates.