If you are a gaming venue, by now you would have received your online compliance report from AUSTRAC. This online survey contains questions regarding your Anti-Money Laundering & Counter Terrorism Finance compliance. My advice to you when completing this report is simple, tell the truth!
Occasionally, Managers are tempted to complete this online survey dishonestly. When asked if they have fulfilled their annual requirements you are faced with a couple of options: Implemented, Not Yet Implemented or N/A. Unfortunately, without considering the consequences some venues simply select the option, Implemented, knowing full well this isn’t the case. This will only end in heart ache when you get audited because it won’t just be a matter of not having the requirements in place; it will be an issue of concealing your noncompliance. In other words, lying to AUSTRAC.
A venue with more than 15 gaming machines is required to be on top of the following:
- Training for staff at regular intervals;
- An up to date AML/CTF program;
- An annual independent audit of your program compliance.
AML/CTF legal requirements can be confusing and we often find venues making the same mistakes. We have listed the top four common misconceptions here:
- The TAB and UBET program is NOT the Club program. They are third party programs which do not cover your own gaming responsibilities. You need your own AML/CTF program.
- An audit of your program shouldn’t be done by the person who manages the gaming. It should be an independent person i.e. not someone involved with facilitating gaming transactions.
- A program is an outline of HOW TO COMPLY with AML/CTF requirements. Not just a description of what you should comply with. It should contain specifics like what and when to report information, how and who to report it to, what forms to use, and where to find them.
- Your staff must be trained on how to follow the program. They must have an understanding of their obligations and be able to answer questions about AML/CTF requirements. We recommend annual training due to the high staff turnover in hospitality.
In recent times AUSTRAC has been attending venues and auditing their compliance. It’s just a matter of time until an auditor finds the venues who were dishonestly reporting on their compliance. It’s better to be honest and open about your situation and seek the correct advice, than be caught out as non-compliant and telling fibs.
Lighthouse Safety has helped many venues manage their AML/CTF obligations. Give Patrick a call on 0422 669 631 if you have any questions, or need assistance. We are always happy to help.