AML/CTF 2025 Updates: What Pubs and Clubs Need to Know
After reviewing and cross-referencing the new October 2025 AML/CTF Guidance Materials against the previous version, there are no dramatic overhauls. However, there are some meaningful refinements worth highlighting.
For pubs and clubs, these changes tighten expectations around governance, compliance oversight and staff accountability. Below is a practical summary of what’s changed and what you should do next.
1. Governance and Oversight
What’s changed:
The 2025 Rules now make it explicit that your Compliance Officer must report to your governing body (Board or Committee) at least annually. This report should cover:
- How well your AML/CTF policies are working,
- Whether your controls adequately mitigate ML/TF/PF risks, and
- Compliance with the AML/CTF Act and Rules.
What it means for you:
Make sure your AML/CTF Program (Part A) is formally approved by your governing body and that there’s documented evidence of the Compliance Officer’s annual report such as board papers, meeting minutes or compliance packs.
2. Compliance Officer Role
What’s changed:
The role itself hasn’t changed, it still must be at management level. However, there’s now an explicit governance reporting requirement (see above).
What to do:
Keep evidence that your Compliance Officer sits at a management level and that reporting to the governing body actually happens. Agendas, minutes and supporting documents are your proof.
3. Risk Assessment
What’s changed:
The structured approach remains: identify → assess → control → monitor → review. The updated Guide provides examples, including how to use a risk matrix and track control responses.
What to do:
Maintain a current, dated risk register. Document your control monitoring and review cycles, especially if risk triggers (like new products or staff turnover) prompt a review.
4. Training and Awareness
What’s changed:
Training must now be role-specific and ongoing. The Guide also suggests extending training to board members, senior managers and consultants.
What to do:
Provide AML/CTF induction and refresher training that’s tailored to each role (e.g., gaming, bar, finance and management). Record your content, frequency and attendance. This will make your next audit much easier.
5. Employee Due Diligence (Integrity and Competency)
What’s changed:
The focus is now broader from just “screening” roles to assessing both integrity and capability before and during employment. It also emphasises what to do when issues arise (such as refresher training or disciplinary action).
What to do:
Create a simple integrity and competency register showing checks completed, dates and outcomes. Define a clear consequence pathway for non-compliance.
6. Independent Review
What’s changed:
No specific frequency has been introduced, but the expectation remains clear. Your AML/CTF Program should undergo regular independent review.
What to do:
Plan for an annual or biannual review, document findings and ensure the board is informed of outcomes and actions taken.
7. Record-Keeping
What’s changed:
Retention periods (7 years) remain unchanged, but the Guide stresses the importance of secure, auditable and privacy-compliant storage.
What to do:
Check that your systems (e.g. ComplianceTrackr or internal file management) allow quick retrieval for audits. Ensure your privacy notices align with these practices.
8. Thresholds and Reporting
What’s changed:
The key clarification is that reporting obligations are determined by the number of EGM entitlements, not the number of active machines.
What to do:
If your venue holds 16 or more EGM entitlements, make sure your Threshold Transaction Reports (TTRs) and Annual Compliance Report processes are up to date.
9. Tipping-Off and Privacy
What’s changed:
No new rules, but a clear reminder that tipping-off remains a criminal offence and privacy obligations still apply even where your entity may otherwise be exempt under the Privacy Act.
What to do:
Update training and your incident/Suspicious Matter Reporting (SMR) procedures to reinforce confidentiality and data handling expectations.
Final Thoughts
While the October 2025 AML/CTF updates may not represent sweeping reform, they raise the bar on documentation, oversight and accountability particularly for larger venues with board or committee structures.
If your venue’s AML/CTF Program hasn’t been reviewed recently, now’s the time to refresh it especially around:
- Governance reporting and recordkeeping,
- Tailored training and employee integrity checks, and
- Risk registers and review cycles.
Need Help Simplifying your AML/CTF Obligations?
We offer a packaged solution tailored for pubs and clubs including updated templates, training and risk registers aligned with the 2025 Guidance.
View 2025 AML/CTF Packages Here
Reach out for a chat if you’d like to make compliance easier, more consistent, and audit-ready.
