High‑Value Dealers, Pubs and Clubs
Guard your business with state-of-the-art Tranche 2 compliance.
AML Smart Guard gives high‑risk sectors a single, industrial‑strength AML platform and service so you can meet higher expectations without grinding the business to a halt.
One Platform – One Service – One Solution affords:
AUSTRAC’s Expectations
AUSTRAC regards dealers in precious metals, stones and high‑value products accepting cash/virtual‑asset payments A$10,000+ (including linked transactions) as well as pubs and clubs with gaming machines (16 or more), as key cash‑intensive sectors that can be used to clean illicit funds.
From 31 March 2026, safekeeping and transfer instructions, become designated services, and all value transfer providers will face updated “travel rule” expectations.
You will need to show you can spot regulated transactions and suspicious play, not just ring up the sale.
From 1 July 2026, AUSTRAC expects you to:
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AML compliance shouldn’t feel like a one-off project or a blank cheque. It should protect your business, support growth and scale as you do.
AML Smart Guard delivers end-to-end Tranche 2 compliance through one simple monthly subscription combining expert guidance, practical implementation and enterprise-grade technology so you can operate with clarity, control and confidence.
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No matter what plan you start on, AML Smart Guard’s comprehensive services and fundamentals remain your safety net:
Standard
Essential compliance for small businesses
$349
/ month
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Best for steady transaction volumes and multi-site businesses
$549
/ month
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Built for higher-volume or multi-office operations
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Not sure which plan? For complex, high-volume businesses with tailored, project-like requirements (e.g. insolvency practitioners), or in need of dedicated support
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Why AML Smart Guard?
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AML Smart Guard is the complete solution. From getting AUSTRAC ready, to client onboarding, ongoing monitoring and reporting, AML Smart Guard offers intuitive design, automation, full support, training and a knowledge centre in one fully compliant package.
AML Smart Guard empowers all Tranche 2 affected businesses to own their AML/CTF risk mandate through our experience, our partnerships, trusted platform and delivery know how; we provide the people, processes and technology to deliver your AML program.
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AML Smart Guard’s people, processes and technology are ready-made to deliver your AML program. No one else provides the same comprehensive combination of platform, service and solutions to assure you remain compliant with ready access to:
We offer the highest level of protection for your business, assuring the effective and pragmatic delivery of your AML program and extend our professional services to advise and support your bespoke needs e.g.,
We’re certain no one else does this; test the market and see for yourself. Our solutions, Our service, Your outcome.
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AML Smart Guard’s Australian leadership team have decades of career long experience in risk and compliance solutions delivered and supported for both Australian and international banks and financial services firms.
Tranche 2 is an Australian problem. Our people live in the same regulatory environment you do, follow AUSTRAC’s updates as they land, and work every day with real estate, legal, accounting, corporate, gaming and digital‑asset clients facing the 1 July 2026 deadline.
We combine local AML/CTF expertise with practical experience inside Aussie firms, so when you call, you’re talking to someone who understands how your trust account works, how your practice software behaves, and what AUSTRAC is actually likely to look for in your sector.
Why a local team matters?
With AML Smart Guard’s local Australian team, you’re getting an enterprise platform and expert delivery partner who understands AUSTRAC, understands your industry, and is here in your time zone to keep you confidently compliant.
Frequently
asked questions
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High‑value dealers, pubs and clubs should focus on building a simple, risk‑based program that controls large cash and virtual‑asset flows, rather than just adding paperwork around the till. Know exactly when you are “in scope” and map regulated activities:
- Run a practical ML/TF risk assessment:
Assess risk by product (bullion, jewellery, luxury goods, gaming), payment type (cash, card, crypto), customer profile (walk‑in, VIP, organised groups), venue/location and delivery channel (in‑person, online, auction). This drives how strong your checks, limits and monitoring must be. - Define when and how you identify customers:
Decide when you must do CDD e.g., above certain cash/crypto thresholds, on payouts, for large chip or ticket‑in/ticket‑out transactions, and what ID and ownership information you collect. Keep procedures simple enough that frontline staff can follow them during busy shifts. - Set rules on what payments you will and won’t accept
AUSTRAC expects you to think about whether you limit or ban certain high‑risk payment types or amounts (for example, large cash, specific crypto assets) and how you detect linked transactions designed to stay just under A$10,000. - Write down processes for red flags and escalation
Capture typical red flags, rapid consecutive purchases, 3rd‑party payers, customers refusing ID, repeated large payouts, unusual betting or play patterns and spell out how staff pause, escalate and record these situations. - Governance, training and testing
Appoint a compliance officer, get the program approved by senior management/board, train all relevant staff, and plan regular testing so you know the program actually works on the floor.
- Check if you must enrol
Use AUSTRAC’s “check if you need to enrol or register” tools and sector guidance for pubs, clubs and dealers to confirm your obligations. - Enrol with AUSTRAC
Complete the online AUSTRAC Business Profile Form with details of your business structure, licences, number of EGMs (for venues), types of high‑value goods, payment methods accepted, ownership and key persons, and keep it up to date. - Build or uplift your AML/CTF program
Use AUSTRAC’s pubs‑and‑clubs guide and jeweller/high‑value‑dealer starter kits as a base, then adapt them to your venue or store including ML/TF risk assessment, governance, CDD, monitoring, reporting, record‑keeping and training arrangements. - Develop an implementation plan
If you cannot be fully ready by the commencement dates, AUSTRAC expects a documented implementation plan approved by senior management or the board, showing how and when you will close gaps. This plan should include control ownership, monitoring and testing steps. - Embed controls into POS and gaming systems
Configure your POS, ticket, loyalty and gaming systems so that:- they flag and aggregate relevant cash/crypto transactions
- they trigger prompts for ID checks and manager approval
- they capture the data you need for reporting and audits
Live CDD
- Staff know exactly when to ask for ID e.g., when a customer buys high‑value goods with cash/crypto near or above the threshold, or when gaming activity hits set limits.
- ID is verified (and, where relevant, recorded in your system) before you complete a regulated transaction or pay out large winnings.
- Higher‑risk customers (e.g., repeat large‑cash players, customers linked to adverse behaviour, or complex purchasing patterns) are subject to extra questions or checks.
Live monitoring
- Your systems aggregate multiple transactions by the same customer or related customers to spot attempts to stay under the A$10,000 threshold.
- Venues monitor gaming, payout and redemption patterns for behaviour consistent with money laundering (e.g., minimal play, rapid cash‑out, use of others to cash tickets).
- Dealers and auctioneers monitor purchases and sales of high‑value items for unusual pricing, 3rd‑party payments or repeated buying/selling of the same goods.
Escalation and reporting
- Staff can quickly escalate concerns to a manager or compliance officer, who decides whether to refuse or delay a transaction, ask for more information, or let it proceed with a note.
- Where behaviour looks suspicious, the business documents what was seen and lodges a suspicious matter report with AUSTRAC within required timeframes.
- Records of ID checks, transactions, risk assessments and reports are kept for at least 7 years in an accessible form.
Done well, your AML program becomes part of how the bar, cage or sales floor operates: prompts at the register, clear scripts for staff, sensible limits and an escalation path not a separate pile of forms no one uses.
Let us worry about AML compliance while you focus on your business.
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