AML/CTF – compliance assistance for smaller gaming
It really is great to see that AUSTRAC has published 2 guides to
help small gaming venues meet their obligations under AML/CTF laws.
The guides were developed with the help of industry and outline a
fairly simple step-by-step process to help identify ML/TF risk,
develop a plan for managing the risk and establish good record
keeping and reporting. For the gaming sector, these guides follow
the 2010 compliance guide AUSTRAC issued for bookmakers.
For this purpose, "small" gaming venues are those with
at least 16 and up to 100 gaming machines, or where the venue is
part of a group of related venues that collectively have 16 to 100
machines. Venues with 15 or less machines are exempt from most of
the obligations under AML/CTF law (for example, they don't have
to adopt an AML/CTF program) and therefore won't have any need
for the guides.
The first guide (AML/CTF compliance guide) steps through the
following 6 modules:
enrolling with AUSTRAC;
examples of money laundering;
conducting an ML/TF risk assessment;
writing the program;
record keeping; and
Each module provides explanation and examples, as well as
additional things that need to be considered and addressed.
The second guide (ML/TF risk assessment guide) is presented by
AUSTRAC as one method a venue might use to identify its ML/TF
risks. The guide takes the venue through the following 6 steps:
venue business description;
establishing the context by reference to customer type and
service deliver methods;
It will be important for any user of the guides to take care in
using the guides and to fully answer and address all the things
raised in them. AUSTRAC makes it clear that the guides set a
benchmark for the level of care, diligence and detail AUSTRAC
expects of small gaming venues.
For venues or venue groups with more than 100 machines, AUSTRAC
clearly indicates the guides will not be enough. We agree. Our
experience with advising larger gaming operators on how to identify
and manage their ML/TF risks bears that out.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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