What Hospitality and Gambling Venues Need to Know
The anti-money laundering and counter-terrorism financing (AML/CTF) landscape in Australia has changed significantly, and hospitality and gambling venues need to be ready.
The reformed AML/CTF framework commenced on 31 March 2026, introducing a more outcomes-focused approach to compliance. For pubs, clubs and other gambling venues, the focus is no longer simply on having policies and procedures in place. Businesses must now be able to demonstrate that their AML/CTF program is effective, understood by staff and actively implemented throughout the organisation.
One of the first areas AUSTRAC may examine is staff training.
If your team does not understand their AML/CTF responsibilities, your venue could be exposed to financial crime risks, regulatory scrutiny and potential enforcement action.
What Has Changed?
The 2026 reforms represent the most significant update to Australia’s AML/CTF framework in many years.
Under the previous model, businesses often focused heavily on following prescribed requirements and maintaining documentation. While documentation remains important, the new framework places greater emphasis on outcomes and effectiveness.
In practical terms, venues must be able to demonstrate that:
- Staff understand their AML/CTF responsibilities
- Risks are identified and managed appropriately
- Customer Due Diligence (CDD) processes are being followed
- Suspicious activity is recognised and escalated
- AML/CTF controls are working as intended
- Compliance is embedded into everyday operations
For gambling venues, this means ensuring all relevant team members understand how to identify potential money laundering or terrorism financing risks and know what actions to take when concerns arise.
Important Compliance Deadlines
Existing reporting entities, including gambling venues, should also be aware of key administrative obligations. AUSTRAC requires reporting entities to maintain current enrolment details, including information about their nominated AML/CTF Compliance Officer. Ensuring these details are accurate and up to date is an important part of maintaining compliance under the new framework.
Why Staff Training Matters More Than Ever
AML/CTF compliance is not the responsibility of a single person.
While venues may appoint an AML/CTF Compliance Officer and have support from senior management, effective compliance relies on staff across the organisation understanding their role in preventing financial crime. Frontline employees are often the first people to notice unusual customer behaviour, suspicious transactions or attempts to avoid identification requirements.
Without appropriate training, warning signs can easily be missed.
Effective AML/CTF training helps staff:
- Understand how money laundering and terrorism financing can impact businesses and communities
- Recognise suspicious behaviours and high-risk activities
- Apply Customer Due Diligence requirements correctly
- Know when and how to escalate concerns
- Protect themselves, their colleagues and their venue from regulatory and reputational risks
Creating awareness across the entire workforce is one of the most effective ways to strengthen a venue’s AML/CTF program.
Understanding Customer Due Diligence (CDD)
One of the key concepts under the reformed framework is Customer Due Diligence (CDD).
CDD involves understanding who customers are and assessing whether they may present a higher risk of money laundering or terrorism financing. While not every customer presents the same level of risk, venues must be able to identify situations that require additional scrutiny.
Examples may include:
- Customers attempting to avoid identification requirements
- Unusual gambling activity that appears inconsistent with normal behaviour
- Transactions involving large amounts of cash without a clear explanation
- Customers acting on behalf of another person
- Behaviour that appears designed to conceal the source or destination of funds
Staff do not need to become investigators. However, they do need sufficient knowledge to recognise warning signs and follow venue procedures when concerns arise.
Building a Strong AML/CTF Culture
One of the strongest messages coming from the reforms is that AML/CTF compliance should become part of everyday business operations.
A strong compliance culture exists when:
- Leaders actively support compliance obligations
- Policies are understood and followed
- Staff feel confident raising concerns
- Training is provided regularly
- Compliance is viewed as a shared responsibility
When AML/CTF awareness becomes part of daily decision-making, venues are better positioned to detect risks early and respond appropriately.
Keep Your Team Current with AML/CTF Training
To help hospitality and gambling venues meet their obligations under the new framework, Zealifi has created a new online course – AML/CTF Awareness & Responsibilities to align with the 2026 reforms. The course has been designed specifically for hospitality and gambling environments and provides practical, easy-to-understand guidance for staff, supervisors, managers and compliance personnel.
What the Course Covers
- What's changed under the 2026 AML/CTF reforms
- Customer Due Diligence (CDD) fundamentals
- Recognising suspicious behaviour and financial crime risks
- Escalation and reporting responsibilities
- Building AML/CTF awareness across your organisation
- Understanding individual responsibilities at all levels of the business
Ready to Strengthen Your Venue's Compliance?
The 2026 reforms are already in effect, making now the ideal time to review your AML/CTF program, update staff knowledge and ensure your venue is prepared for the new regulatory environment.
Explore Zealifi’s AML/CTF Awareness & Responsibilities Online Course today and help your team build the knowledge and confidence needed to identify risks, support compliance and protect your business.
