Transaction Monitoring


All Hotels and Clubs offering gambling services must have an Anti-Money Laundering Counter-Terrorism Program (AML/CTF) in place. A separate program is required for each gambling type. For example, separate programs are needed for TAB and Gaming Machines.
A major component of the AML/CTF Program is a Transaction Monitoring Program (TMP). Transaction Monitoring policies and procedures enable Hotels, Pubs, and Clubs to identify suspicious transactions. Policies and procedures will incorporate staff vigilance and systems analysis.
All venues with gaming machines are “reporting entities” and must report all suspicious transactions no matter how small and cash transactions of over $10,000 to AUSTRAC. The venue’s TMP procedures facilitate the identification of suspicious transactions.
Suspicious transactions mean a transaction that gives reasonable grounds for suspicion that it may be involved in a crime or that it may be facilitating tax evasion.
Suspicious and transactions reaching the transaction thresholds must be reported to AUSTRAC within 24 hours. Suspicious transactions maybe for hundreds of dollars as well as thousands of dollars. These transactions will also be highlighted in the Annual Compliance Report to AUSTRAC.
The Transaction Monitoring policies and procedures should be clearly outlined in the Venues AML/CTF Program.
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.

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