COVID-19, AUSTRAC, Pubs and Clubs

AUSTRAC are constructively working with Pubs and Clubs to assist manage Money Laundering and Terrorism Financing (ML/TF) risks during this disruptive period of COVID-19. This includes considering circumstances for Pubs and Clubs when applying the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws.


SMR reporting for Pubs and Clubs during COVID-19

AUSTRAC are still encouraging Pubs and Clubs to monitor and report an SMR for any suspicious customer and/or gaming machine player. If a customer is deemed to be suspicious, Pubs and Clubs have 24 hours to submit an SMR if the suspicion is terrorism-related or 3 days to submit an SMR for any other suspicion.  Fines for non-compliance will still apply.

AUSTRAC has identified areas of criminal exploitation where the financial system may be more vulnerable during the COVID-19 pandemic. The main exploitation that relates to Pubs and Clubs is the movement of large amounts of cash following the purchase or sale of illegal or stockpiled goods.  Staff must be trained to look out for suspicious playing behaviour such as placing large amounts of cash into the machine or not playing the machine for long before collecting their funds.

AUSTRAC would like to be informed of any significant shifts observed in relation to your financial crime and fraud monitoring, which can then be shared more widely to inform the Pubs and Club industry. To do this, please contact AUSTRAC via the online form.

More information regarding SMR Reporting for Pubs and Clubs can be found on the AUSTRAC website or you can contact us on (02) 9544 7044 /


 How to comply with KYC requirements during the COVID-19 pandemic

AUSTRAC has recognised that businesses may face additional challenges in complying with customer verification obligations under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) rules during the COVID-19 pandemic.

Pubs and Clubs, however, are still obligated to collect, verify and record appropriate information for every cheque payout.  AUSTRAC has amended the rules during the COVID-19 pandemic, allowing businesses to accept copies of the applicable documentation however if the player collects their winning at the time of payout, there is no valid reason why the original document cannot be produced.


For further information about AUSTRAC rule update during the pandemic, please refer to the AUSTRAC website.


The AML Company are experts in Pub and Club AML/CTF compliance. We offer cost-effective and compliant AML/CTF Program solutions to Pubs and Clubs in Australia.
We have been providing AML/CTF compliance programs to the pub and club industry for over 15 years. The AML Company is a boutique company that has provided Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Risk Analysis to Clubs, Pubs, and Financial Institutions for the past 15 years.  Our business focus is on AUSTRAC regulations as they pertain to gaming machines within Pubs and Clubs. We aim to make compliance with regulations as easy as possible for our clients.