ML/CTF – compliance assistance for smaller gaming venues

It really is great to see that AUSTRAC has published 2 guides to help small gaming venues meet their obligations under AML/CTF laws. The guides were developed with the help of industry and outline a fairly simple step-by-step process to help identify ML/TF risk, develop a plan for managing the risk and establish good record keeping and reporting.  For the gaming sector, these guides follow the 2010 compliance guide AUSTRAC issued for bookmakers.

For this purpose, “small” gaming venues are those with at least 16 and up to 100 gaming machines, or where the venue is part of a group of related venues that collectively have 16 to 100 machines.  Venues with 15 or less machines are exempt from most of the obligations under AML/CTF law (for example, they don’t have to adopt an AML/CTF program) and therefore won’t have any need for the guides.  

The first guide (AML/CTF compliance guide) steps through the following 6 modules:

  • enrolling with AUSTRAC;
  • examples of money laundering;
  • conducting an ML/TF risk assessment;
  • writing the program;
  • record keeping; and
  • compliance reports.

Each module provides explanation and examples, as well as additional things that need to be considered and addressed.

The second guide (ML/TF risk assessment guide) is presented by AUSTRAC as one method a venue might use to identify its ML/TF risks. The guide takes the venue through the following 6 steps:

  • venue business description;
  • establishing the context by reference to customer type and service deliver methods;
  • identifying the venue’s ML/TF risks;
  • how the venue treats those risks;
  • allocating ratings to the risks; and
  • identifying change in the risks.

The guides can be downloaded from the Guides page of the AUSTRAC website (

It will be important for any user of the guides to take care in using the guides and to fully answer and address all the things raised in them. AUSTRAC makes it clear that the guides set a benchmark for the level of care, diligence and detail AUSTRAC expects of small gaming venues.

For venues or venue groups with more than 100 machines, AUSTRAC clearly indicates the guides will not be enough. We agree. Our experience with advising larger gaming operators on how to identify and manage their ML/TF risks bears that out.