5 Signs Your AML/CTF Program Might Be Outdated (and What to Do About It)
Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) has become a major focus for regulators, particularly in the club and gaming sector. Venues across Australia are expected to identify, assess and manage the risks of money laundering and terrorism financing and AUSTRAC is paying close attention.
Yet, many clubs and venues are unknowingly falling behind on their obligations.
So, how confident are you that your AML/CTF program is up to date? Here are five key questions every General Manager, HR Manager and Compliance Officer should be asking.
1. When was your last AML/CTF risk assessment?
Your AML/CTF risk assessment should be reviewed at least every two years or whenever there are changes in your operations, structure or customer profile.
If you can’t remember the last time it was updated, your venue may be operating on outdated assumptions about where your risks actually are.
2. Do you know who qualifies as a Politically Exposed Person (PEP)?
Your AML/CTF risk assessment should be reviewed at least every two years or whenever there are changes in your operations, structure or customer profile.
If you can’t remember the last time it was updated, your venue may be operating on outdated assumptions about where your risks actually are.
3. Has your AML/CTF Program been reviewed or updated in the last five years?
Your AML/CTF risk assessment should be reviewed at least every two years or whenever there are changes in your operations, structure or customer profile.
If you can’t remember the last time it was updated, your venue may be operating on outdated assumptions about where your risks actually are.
4. When did you last log into your AUSTRAC portal?
Regularly accessing your AUSTRAC portal helps ensure your venue details, compliance contacts and reporting obligations are current.
If your portal login details are buried in an old inbox or no one remembers the last time you logged in, that’s a red flag.
5. Would your staff know how to recognise and report a suspicious transaction?
Training is not a “set and forget” obligation. Your team should be confident in identifying suspicious behaviour, structuring and red-flag indicators and know exactly how and where to report it.
Ongoing, trackable training is essential especially given the high turnover often seen in hospitality and gaming environments.
If you answered “no” or “not sure” to any of the above…
You’re not alone, but it’s time to act.
AUSTRAC expects venues to demonstrate a proactive and documented approach to AML/CTF compliance. That means risk assessments, training, program updates and reporting processes must all be clear, current and evidence-based.
How we can help
We support clubs and venues across Australia with practical AML/CTF solutions, including:
- Tailored risk assessments
- Program reviews and updates
- Staff training on AML/CTF awareness and reporting
- Independent reviews and audit preparation
And all of it is delivered through our secure digital platform, ComplianceTrackr.
Powered by ComplianceTrackr - your all-in-one compliance hub
ComplianceTrackr makes AML/CTF compliance simple and centralised:
- Secure storage for AML/CTF documentation and risk assessments
- Digital staff training via web or app, with tracking and completion reports
- Real-time dashboards and audit-ready reporting
- Suspicious Matter Reports (SMRs) can be completed and logged directly in the platform
Stay compliant. Stay confident. Stay audit-ready.
Get in touch today to review your AML/CTF obligations and explore our compliance packages.
