“Money laundering doesn’t happen at our venue” – a common sentiment Alexandra Hoskins, Principal at Senet often hears from venue staff across Australia.
However, the reality is that venues are a prime target for money laundering. With more than 185,000 Electronic Gaming Machines (EGMs) and over $100 billion flowing through them annually, gaming venues provide ample opportunities for criminals to exploit compliance gaps.
“When I ask venues how confident they are that their existing AML/CTF program is fit for purpose and that their procedures are working effectively, it’s often met with some hesitancy and uncertainty,” Alexandra explains. “Even for venues with a dedicated compliance resource, compliance can still seem complicated and feel overwhelming. But it doesn’t need to be if processes and procedures are fit for purpose and easy to follow.”
Money launderers use over 20 methods to disguise the proceeds of crime. If venue staff are not equipped with the knowledge to identify these methods and act appropriately, unusual or suspicious activity can easily go unnoticed. This false sense of security not only leaves venues vulnerable to exploitation but also exposes them to significant regulatory and reputational risks.
As the annual AUSTRAC AML/CTF Compliance Report deadline approaches, venue CEOs and AML/CTF officers should assess their AML/CTF Program, Risk Assessment and Transaction Monitoring Program, so they are not exposed to unnecessary risks, especially legal and regulatory non-compliance.
Preparing for the AUSTRAC AML/CTF Compliance Report
The AML/CTF Compliance Report, due by 31 March, is a critical compliance deliverable for venues. Compliance requirements vary based on the number of EGMs a venue is licensed to operate:
• 15 or fewer EGMs: Venues must enrol with AUSTRAC, keep updated records, submit Suspicious Matter Reports (SMRs) but are not required to submit a compliance report.
• 16 or more EGMs: Additional obligations include appointing a Compliance Officer, implementing an AML/CTF program, conducting annual risk assessments, undertaking Customer Due Diligence (KYC), transaction monitoring, and ensuring that independent reviews occur regularly (at least every 2 to 3 years for high-risk venues).
• Even venues with fewer than 16 EGMs (but licensed for more) must comply with the stricter requirements. Failure to meet these can lead to enforcement actions.
The Costs of Non-Compliance
Without a fit-for-purpose AML/CTF Program and for failures to comply with that Program and the legislation more broadly, venues risk:
• Fines and Civil Penalties: Up to $33 million per contravention for corporate breaches.
• Actions: Including forceable undertakings and external audits.
• Reputations Damage: Undermining consumer trust and business viability.
Tailored AML/CTF Programs, Not One-Size- Fits-All
AUSTRAC has made it clear that AML/CTF programs must be tailored to a venue’s specific risks. Generic, off-the-shelf programs are not acceptable and often leave businesses exposed to significant risks.
Tailored programs, developed through site visits and venue-specific risk assessments, provide the best protection.
HOW SENET CAN HELP
Senet’s approach to AML/CTF compliance is informed by industry knowledge and direct engagement with AUSTRAC, delivering tailored solutions that withstand regulatory scrutiny. They work closely with regional and metropolitan venues, ensuring compliance is clear, practical, and seamlessly integrated into daily operations.
Here’s how they support you:
• Independent Reviews: Senet conduct a detailed review of existing AML/CTF frameworks and provide easy-to-follow, actionable recommendations that integrate into existing venue processes.
• Tailored AML/CTF Programs: Senet develop customised AML/CTF programs tailored to the venue, ensuring it’s easy to implement and designed to meet regulatory standards and withstand scrutiny.
• Risk Assessments: Using over 30+ variables, including a site visit, the team will assess the specific AML/CTF risks venues reasonably face and advise on tailored controls to effectively mitigate risks.
• Staff Training: Senet help everyone understand money laundering risks in venues and their compliance responsibilities through targeted AML/ CTF and Safer Gambling training for frontline staff and board members, both online and in person.
• Ongoing Support: Your venue receives ongoing year-round support with access to Senet’s essential online resources with best-practice tools, templates, updates, and training packs to help facilitate implementation.
BOOK A FREE CONSULT
Schedule a free video consultation with our experts to ask any compliance-related questions and explore how we can help your venue navigate its AML/CTF obligations with confidence.
Visit www.senetgroup.com/aml-consult to get started. or contact Alexandra Hoskins
P: +61 423 726 904
E: alexandra@senetgroup.com