Pub and Club Venues: The Regulatory Shift
Australia has been tightening its AML/CTF (Anti-Money Laundering /Counter-Terrorism Financing) framework significantly, with gaming venues — pubs, and clubs (and casinos) — squarely in focus of the shift from education to expectation.
The Core Change: AML Reforms
The core shift in pub and club regulation, particularly for businesses with entitlement to operate 16 or more electronic gaming machines (EGMs) and/or multi-terminal gaming machines (MTGMs), is the Anti-Money Laundering (AML) Reforms introduced on 31 March 2026. What does this mean in practice? We examine two key areas of Customer Due Diligence and Risk Assessment in this article – which is part of a series of three articles.
Customer Due Diligence (CDD): Venues must now verify the identity of patrons at a lower threshold of $5,000 for a payout or linked payout.
- Know Your Customer (KYC) requirements apply to these lower threshold transactions. This means:
- Collecting names, DOBs, addresses, occupation, and identification (ID) — and verifying the information to confirm the person is who they say they are,
- Determining a customer risk-rating relating to money-laundering (ML) risk – including determining any politically exposed persons (PEPs) or related parties to PEPs, and
- Where required, collecting and verifying further information about any patrons that may present a higher level of ML risk – known as enhanced customer due diligence (ECDD).
- Transaction Monitoring (TM) - that can also trigger ECDD - is used to identify a wider range of risk indicators at different times in the gaming experience, for example:
- Money coming in,
- Winnings paid out,
- Gambling activity, and
- Interaction with floor, cashier, and other venue staff.
Risk Assessment: Requiring a broader consideration of risks, including proliferation financing, and circumstances that may give rise to differences in money laundering risks, for example:
- Whether customers play carded or uncarded,
- How long customers are present relative to their declared occupation, and
- For clubs, whether members vs visitors/guests present different risks.
Taking directly from the updated guidance for Pubs and Clubs with EGMs in October 2025[1]:
In addition to the process of laundering funds, pubs and clubs are exposed to the risk of individuals spending funds from criminal activity for EGM play.
Dealing in the proceeds of crime is a criminal offence and venues should consider this as part of their risk assessment and transaction monitoring programs.
The October 2025 guidance also added new areas of risk focus relating to:
- Maximum cash insertion limits per EGM/MTGM,
- High-value EGM concentration,
- Locality-based risk, for example loan sharking, and
- Multi-venue enterprise risk assessment requirements.
From educate, to expect – regulatory posture
Leading up to the 2026 reforms, AUSTRAC’s regulatory expectation has been clear – whether through their CEO’s public statements or from enforcement action – a shift from being educated, to expecting financial crime risk management.
Other key regulatory expectation themes include:
- Technology helps sustain and scale transaction monitoring systems and CDD platforms.
- Staff training for front-of-house staff is contemporary to provide the knowledge to recognise ML risk indicators, and take steps to mitigate and manage risks.
- Policies are written with overarching AML/CTF programs and in practice that they are actually followed.
- Record-keeping aligning to the 7-year retention of records that are easily accessible and tell a clear story of why actions were taken.
- Legal exposure is real and penalties can be substantial - ignorance is not a defence.
