AML/CTF
AML/CTF Obligations Register for Clubs with EGMs - Template
July 2026 · Lane Consulting & Advisory
This is not legal advice
This register is a compliance consulting tool prepared by Lane Consulting & Advisory (LCA). It summarises, in plain English, obligations under the AML/CTF Act 2006 (as compiled to 1 July 2026) and AML/CTF Rules 2025 (as compiled to 31 March 2026), together with related AUSTRAC guidance. LCA does not provide legal advice, and nothing in this register should be treated as such. It is general guidance only, does not cover every circumstance, and must not be relied on as a substitute for reviewing the primary legislation or obtaining independent legal advice on the club's specific circumstances.
Who this register is for
This register is designed for registered clubs - RSL, leagues and bowls clubs - licensed to operate one or more electronic gaming machines (EGMs). It covers the obligations that apply to clubs as reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the Act) and the AML/CTF Rules 2025 (the Rules), reflecting the post-reform framework that commenced 31 March 2026.
Under section 20 of the Act, a club providing services to its members is still treated as carrying on a business - the fact that a club is member-owned or not-for-profit does not take it outside the regime. Most clubs are reporting entities because they provide a designated service under table 3 of section 6 of the Act by allowing patrons to play EGMs, and by exchanging or paying out tickets, tokens or winnings connected with those machines.
Two important scope checks before using this register
- Other designated services: If the club also provides stored value cards, international remittance, or other designated services, those carry their own obligations not fully covered here. Extend the register to cover them.
- Leased or shared EGM arrangements: If the club does not own or lease its own gaming machines, section 13 of the Act determines who is the "controller" of the venue for AML/CTF purposes. Confirm who the correct reporting entity is before assuming it is the club.
How to read the register
The register is structured as a table with five columns: the obligation area, what it means in practice for the club, the exact Act or Rules section it comes from, when it applies or how often, and where to find AUSTRAC's guidance on the topic.
Figures and dates flagged for verification should be checked against the primary source before being used in a board paper or external communication. The register reflects the Act as compiled to 1 July 2026 and the Rules as compiled to 31 March 2026. Given how recently the reforms commenced, LCA recommends checking www.austrac.gov.au for updates before each board reporting cycle.
The nine obligation areas
The register covers nine sections, each corresponding to a distinct area of AML/CTF obligation.
Getting on AUSTRAC's radar
Enrolment as a reporting entity, keeping enrolment details current, and the rules that apply if the club is related to other reporting entities and forms part of a reporting group. Clubs already enrolled as at 30 March 2026 were required to notify AUSTRAC of their compliance officer by 30 May 2026 - clubs that have not yet done so should treat this as a priority.
Building and running the AML/CTF Program
The core program obligations: ML/TF and proliferation financing risk assessment, AML/CTF policies (procedures, systems and controls), targeted financial sanctions policy, personnel due diligence and training, governing body oversight, the AML/CTF compliance officer role, program documentation and approval, and independent evaluation. The independent evaluation transitional deadline for existing reporting entities is the later of 4 years after the club's most recent independent review, or 31 March 2027.
Knowing the club's patrons (customer due diligence)
Initial CDD, the gaming machine CDD threshold (CDD is triggered on EGM-related exchanges or payouts of $5,000 or more - a separate threshold from the $10,000 TTR trigger), ongoing CDD and transaction monitoring, simplified and enhanced CDD, and keep open notices from law enforcement.
Reporting to AUSTRAC
Suspicious matter reports (SMRs), threshold transaction reports (TTRs) for physical currency transfers of $10,000 or more, international value transfer service reporting (generally not applicable to a typical club), and the annual AML/CTF compliance report. The first reporting period under the new framework runs from 1 July 2026 to 30 June 2027, with lodgement due by 30 September 2027.
Keeping records
Transaction records (7 years from when the record is made), CDD records (7 years from when the business relationship ends or the occasional transaction is completed), and AML/CTF program records (7 years after the record stops being relevant to compliance).
Conduct obligations
Tipping off - the prohibition on disclosing that an SMR has been or is required to be made. False or misleading information provided to AUSTRAC or an authorised officer (up to 10 years imprisonment or 10,000 penalty units per contravention). False customer identity or documents used by patrons to receive a designated service.
A carve-out worth checking: small gaming machine venues
Clubs that, combined with any related entity, hold licences for no more than 15 gaming machines in total and only provide the specific gaming-machine designated services listed in s233K(1)(b) are exempt from most of Part 1A (the AML/CTF program), most of Part 2 (CDD), TTR reporting, and most record-keeping obligations. Suspicious matter reporting still applies regardless. Clubs should confirm their total EGM entitlement across all venues and related entities before relying on this exemption.
Oversight, audit and enforcement
AUSTRAC-directed external audits (risk management under s161 or general compliance under s162), civil penalties for non-compliance (maximum approximately 100,000 penalty units for a body corporate per contravention, at the current penalty unit of $364), and AUSTRAC information and document requests.
Specific AML/CTF Program or Policy Obligations
A club-specific section for obligations that flow directly from the club's own AML/CTF Program or policies. Each row captures what the Program or policy requires the club to do, the relevant section, the frequency or trigger, and the internal owner of the obligation. This section is completed by the club from its own Program documentation.
Key thresholds and deadlines to note
| Item | Detail |
|---|---|
| EGM CDD threshold | $5,000 or more for exchanges or payouts connected with gaming machines |
| TTR threshold | $10,000 or more for physical currency transfers (separate from the EGM CDD threshold) |
| SMR - terrorism financing | 24 hours after forming the suspicion |
| SMR - other grounds | 3 business days after forming the suspicion |
| TTR lodgement | Within 10 business days of the transaction |
| Annual compliance report - first period | 1 July 2026 to 30 June 2027; lodgement due 30 September 2027 |
| Compliance officer notification (transitional) | Due 30 May 2026 for clubs enrolled before 31 March 2026 - treat as priority if not yet done |
| Independent evaluation (transitional) | Due by the later of 4 years after the most recent independent review, or 31 March 2027 |
| Small venue exemption cap | 15 or fewer EGMs in total across the club and all related entities |
| Civil penalty - body corporate | Up to approximately 100,000 penalty units per contravention (current penalty unit: $364) |
| Record retention - transactions | 7 years from when the record is made |
| Record retention - CDD | 7 years from when the business relationship ends |
AUSTRAC guidance referenced in the register
The register links to the following AUSTRAC guidance resources. LCA recommends checking each for updates before each board reporting cycle.
Download the template
The full register is available as a PDF. It includes the obligation table across all nine sections, with legal source references and AUSTRAC guidance links, ready to be adapted for the club's specific circumstances.
Need help?
If your club needs assistance building or reviewing its AML/CTF obligations register, assessing its AML/CTF Program, or conducting an independent evaluation, contact LCA - we conduct independent evaluations and are ready to help.
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Disclaimers: The material contained in this webpage and the attached register is provided by LCA. The contents of this webpage and the attached register do not constitute legal advice and should not be relied upon as a substitute for legal or other professional advice. LCA makes no warranties or representations about the material contained in these documents.