The Three Stages of Money Laundering


The Anti-Money Laundering process can be broken into 3 distinct phases.

1. Placement
Placement is moving, dispersing, or disguising illegal funds to hide their true identity. In the event of cash being obtained from an illegal source and input into a gaming machine, the money has been layered.

2. Layering
An example of layering in a Pub or Club is when a person associated with crime (for example, drugs) uses gaming machines to “clean money.” The person themselves or somebody they have hired will go to the venue with cash, and they will then deposit large amounts of cash and withdraw winnings in the form of a cheque after a short time. Teams of people can be used to go to several venues.
The example used above can also be used to facilitate tax evasion. All cheques for gambling winnings can be deposited in a bank account and are tax-free.

3. Extraction
Extraction is when the funds are withdrawn; for Pubs and Clubs, the majority of these payments will be by cheque.

Should a Hotel or Club require assistance implementing an AML/CTF Program or a component of the Program into their venue, The AML Company can assist. We are a boutique company that specialises in assisting Pubs and Clubs in managing their Anti-Money Laundering and Counter-Terrorism needs. The focus is on ensuring that our clients meet their AUSTRAC obligations. We work to ensure Pubs and Clubs understand AUSTRAC regulations as they pertain to gaming machines. Each of our clients implements an AML/CTF Program. Programs are implemented with the Pub or Club on a face-to-face basis. During the implementation, we will meet with the venue’s General Manager or Licensee. We work with the Compliance Manager to implement policies, procedures, and systems to facilitate the ongoing management of AML/CTF risks. All programs are developed using a risk-based approach. Our methodology is not based on one size fits all. We aim to assist clients in making compliance with AUSTRAC as seamless as possible. The AML Company has been working with Pubs and Clubs in NSW and QLD for 10 years. Following the implementation of a program, we are available to assist clients 7 days a week.

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.

Add comment