AML/CTF Changes for Gaming Venues: What Applies from 31 March 2026 (and What Can Wait)

From 31 March 2026, Australia’s updated AML/CTF framework will begin applying to gaming venues. While recent messaging has created some urgency, and in some cases confusion, the reality is more measured.

Not everything changes at once.

Some obligations must be in place immediately, while others can be transitioned over a three-year period through to 30 March 2029.

This article outlines what gaming venues need to know, where to focus first, and how to approach the changes in a practical, defensible way.

The Key Point: This Is a Staged Reform

The AML/CTF reforms introduce a phased implementation approach:

• Mandatory obligations apply from 31 March 2026
• Certain customer onboarding (CDD) changes can be transitioned through to 2029

Understanding the difference is critical for venues trying to prioritise resources, systems and staff training.

What MUST Be in Place by 31 March 2026

From March 2026, all gaming venues must be able to demonstrate:

• Ongoing Customer Due Diligence (OCDD)

  Monitoring customer transactions and behaviour patterns, including long-standing patrons.

• Suspicious Matter Reporting (SMR)

  No change to existing expectations. Suspicious activity must still be identified and reported promptly.

• Threshold Transaction Reporting (TTR)

  The $10,000 cash threshold remains unchanged.

• Governance and Oversight

  AML/CTF compliance must be actively overseen by directors and senior management.

• Politically Exposed Person (PEP) obligations

  Including enhanced due diligence, source of wealth/funds checks and senior approval.

The Critical Change: $5,000 Gambling CDD Threshold

One change cannot be deferred.

From 31 March 2026, initial Customer Due Diligence must be conducted when a customer’s gambling transactions reach $5,000, reduced from the previous $10,000 threshold.

This applies to:

• Single payouts of $5,000
• Multiple linked payouts totalling $5,000
• Cashless and carded transactions
• Customers who are well known to the venue

In simple terms:

Once a customer’s gambling transactions reach $5,000, the venue must know who they are.

What Can Be Transitioned to 2029

Venues have until 30 March 2029 to transition from their existing Applicable Customer Identification Procedure (ACIP) to the new CDD framework.

During this period:

• Existing CDD methodologies may continue to be used
• Deemed compliance rules are not immediately mandatory
• Delayed CDD provisions remain available
• System and onboarding changes can be staged over time

However, venues must fully comply with whichever framework they choose and cannot mix old and new models.

What AUSTRAC Will Be Looking For

Beyond policies and procedures, AUSTRAC will expect venues to demonstrate:

• A documented CDD framework
• Clear risk-rating processes
• Defined triggers for enhanced due diligence
• Evidence of monitoring, escalation, and decision-making

Ultimately, venues should be able to answer one key question:

“Why did you consider this customer’s behaviour acceptable?”

Download: AML/CTF Transitional Rules for Gaming Venues 2026

To support venues, we’ve prepared a concise, practical guide outlining:

• What applies from 31 March 2026
• What can be transitioned through to 2029
• How the $5,000 threshold works in practice

Download: AML/CTF Transitional Rules for Gaming Venues – 2026 (Safety Mates Australia)

Final thought

AML/CTF compliance isn’t about reacting to noise, it’s about understanding regulatory expectations and applying them in a way that works operationally.

If you need help interpreting what these changes mean for your venue, Safety Mates Australia can support you with practical, venue-focused advice.

We are here to support you wherever you need. Get in touch with us today!