AML Compliance Tools for Gaming, Pubs & Clubs

AML Smart Guard provides AML/CTF compliance tools for gaming venues, pubs and clubs, and dealers in precious metals, stones and products, supporting customer due diligence, risk assessment, transaction monitoring, staff training, record keeping and reporting obligations.

Dealers in precious metals, stones and products became newly regulated under Australia’s expanded AML/CTF regime from 1 July 2026, while pubs and clubs operating gaming machines may already have existing AML/CTF obligations.

What AUSTRAC expects

Venues meeting the 16+ EGM threshold, or handling cash transactions over the A$10,000 reporting threshold, must identify regulated transactions, implement an AML program, detect linked transactions (structuring), report to AUSTRAC within statutory timeframes, and keep electronic records.

Which plan do I need?

Venue type	Recommended plan	Why
Single venue near the 16-EGM threshold or single gaming venue	Flex/Bespoke or Standard	Right-size before committing to a higher screening tier
Multi-venue pub or club group	Scaled or Enterprise	Centralised monitoring across venues, dedicated account manager
Precious metals, stones or products	Standard, adjusted for transaction-based rather than patron-based screening	Different risk profile to a gaming venue

Frequently asked questions

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What should a gaming venue or pub/club focus on when designing its AML program?

Assess the ML/TF risks associated with the venue’s products, customers, payment methods and gaming activity; establish appropriate CDD and monitoring processes; define red-flag and escalation procedures; and ensure relevant staff understand their day-to-day AML/CTF responsibilities.

What does AUSTRAC enrolment and build look like for a venue?

Confirm which designated services and AML/CTF obligations apply to the business, ensure AUSTRAC enrolment details are current, appoint an AML/CTF compliance officer where required, and implement an AML/CTF program and operational processes appropriate to the venue’s risks.

What does “live CDD and monitoring” look like on the floor?

Real-time ID verification when a threshold is triggered, aggregation of linked transactions from the same patron, escalation of unusual patterns, and electronic record-keeping.

Do TAB or wagering terminals count toward the EGM threshold?

No. The relevant threshold relates to the number of electronic gaming machines (EGMs) the venue is licensed to operate. Other wagering services may have separate AML/CTF obligations depending on the designated services provided.