AML/CTF Challenges for the Hospitality Industry in Australia

Leigh BarrettLeigh Barrett, Managing Director and Principal Consultant at Leigh Barrett & Associates shares an overview of AML/CTF Challenges for the Hospitality Industry in Australia. He will be delving further into this topic at the upcoming Liquor and Gaming Law Roundtable 2021 on Tuesday 9 March 2021.


As the reopening of Clubs and Hotel venues with electronic gaming machines (EGMs) and wagering facilities across Australia takes place following lockdowns and border closures due to the COVID-19 pandemic, AUSTRAC, the Australian government agency responsible for detecting, deterring and disrupting criminal abuse of the financial system, has signalled its intention to continue its vigilant scrutiny of the industry’s compliance with the Anti Money Laundering and Counter-Terrorism Financing Act 2006 (the “Act”) and the Anti Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (the ”Rules”). Each
venue with 15 or more EGMs is required to have in place an Anti Money Laundering and Counter Terrorism Financing (AML/CTF) Program, including comprehensive risk-based policies and procedures, that describes in detail the oversight policies and procedures for operations within that venue to ensure the integrity of the industry.

As technology results in streamlining the provision and availability of land-based gaming it is essential, and AUSTRAC requires, that AML/CTF programs account for and respond to these changes such that the systems and procedures reflect the potential risks faced by new designated services and accessibility. Examples of changes in technology include the introduction of automated “note -breaker” facilities in gaming rooms, EGM ticket-in-ticketout incorporating the use of automated cash redemption terminals in Victoria and the potential introduction of EGM bank note acceptors in South Australia.

Recognition and management of high-risk customers, including actual or potential Politically-exposed persons (PEPs), within venues has also attracted increased attention from AUSTRAC during in-venue and desktop reviews. It is critical that AML/CTF systems and procedures adequately address the regulatory obligations of the venue.

Many EGM clubs and hotels do have documented systems and procedures but fall short min the implementation, oversight and review of such. It is essential that staff are well trained and are knowledgeable about their obligations. Senior management and directors must also be well versed in the venue’s AML/CTF compliance requirements. Finally – and this is
where many clubs and hotels fail – AML/CTF programs must be independently reviewed at least every two years.

Recently, the major banks have also significantly increased their AML/CTF focus on clubs and hotels with lines of credit. Leigh Barrett and Associates/Gamesure has assisted a number of clubs and hotels that have been approached by their financial institution requesting copies of AML/CTF programs, independent review reports and other details
regarding oversight and risk assessment/management.

Breaches of compliance with AML/CTF obligations can attract very significant penalties.

Leigh Barrett is one of Australia’s most sought after responsible gambling strategists and recognised expert in regulatory compliance for the gaming and hospitality industry. With a wide range of pertinent qualifications and a strong background in social work, social policy and government regulation, he brings more than 20 years experience to the field of problem gambling, responsible gambling and liquor licensing. He regularly attends key industry forums, think tanks and conferences all around the world as a highly respected guest speaker and working party group co-ordinator. Connect with Leigh via email or LinkedIn LinkedIn