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.
