AML/CTF Compliance — Pubs & Clubs
NewAML/CTFrulesareinforce.Isyourvenueready?
For 20 years, Elite Legal has helped registered clubs and hospitality venues stay ahead of AUSTRAC. Take the free 2-minute compliance check to see exactly where your venue stands under the 2026 reforms.
The 2026 reforms
What changed on 31 March 2026
- 25 Mar 2026
AUSTRAC sector guidance
AUSTRAC published “Indicators of suspicious activity for the pubs and clubs sector.”
- 30 Mar 2026
Transitional Rules made
The Transitional Rules were made and registered under the AML/CTF Amendment Act 2024. They commenced on 31 March 2026 and run to 31 March 2029 (Part 3 ACIP / Initial Customer Due Diligence).
- 31 Mar 2026
Reforms commenced
The reformed AML/CTF Act applies to existing reporting entities — including pubs and clubs with gaming machines.
- Single program
One AML/CTF program
The old Part A / Part B structure is gone. Your AML/CTF Program now consists of your Risk Assessment(s) and Policies (policies, procedures, systems and controls).
- 13 Apr 2026
OAIC privacy guidance updated
The Office of the Australian Information Commissioner (OAIC) updated its Privacy guidance for reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act.
- 30 May 2026
Compliance officer deadline (passed)
Every venue must have a fit-and-proper AML/CTF compliance officer registered with AUSTRAC. If you missed this, you need advice now.
A template program in the drawer, or a two-page independent assessment, is not enough. AUSTRAC expects venues to demonstrate their program works in practice — tailored risk assessments, trained staff, and genuinely independent evaluations that evaluate both compliance and proper implementation.
Your path to compliance
Independent Evaluation
An independent evaluation does three jobs at once: it satisfies the law, it protects your directors, and it tells you exactly what to fix — in plain English, prioritised, board-ready.
Meets the legal requirement
The reformed Act requires your Program to provide for regular, independent evaluation by a suitably skilled, independent person (s 26F(4)(f); Rule 5-10). We are that independent evaluator.
Compliance AND proper implementation
We check the compliance status of not only your risk assessments, program and policies but also your implementation and effectiveness through Transaction Analysis and Staff Interviews.
Board-ready assurance
A clear report the Directors can read and adopt — a clear set of issues for your Senior Manager and Compliance Officer to focus on to improve your program and its implementation.
Your Board is now on the hook
Your Board must now exercise ongoing oversight and take reasonable steps to ensure — the Board must exercise appropriate and ongoing oversight of risk assessments and risks identified, and ongoing effective compliance with AML/CTF policies, the Act, Regulations and AML/CTF Rules.
Free compliance check
Check your venue's compliance
15 questions. 2 minutes. Then a no-obligation 15-minute discussion call with us about your compliance.
Ready when you are
Answer honestly — there are no wrong answers. At the end you can book a free, no-obligation 15-minute call to talk it through with us.
Why us
Why venues choose Elite Legal
A law firm, not a consultancy
Legal rigour on every evaluation — findings anchored to the exact section, Rule and AUSTRAC guidance.
We know you, and talk your language
We understand how your Club works, we know how cash moves, what staffing limitations you have, what your different systems do, and your competing and complementary regulatory obligations.
Club-sector DNA
ClubsNSW Silver Corporate Partner and CMAA Silver Partner. We know the Registered Clubs Act, Liquor Act and Gaming Machines Act as deeply as the AML/CTF Act.
Programs staff actually use
Practical, operational documents — not shelf-ware. AUSTRAC expects programs that match how your venue really runs.
We speak venue, not just statute
We know pubs and clubs from the gaming floor up — the products, the systems and the people:
- EGM & MTGM products
- CRTs vs ATMs
- Gaming Management Systems
- Tiered loyalty programs
- Carded & uncarded play
- Club boards & governance
- Sign-in processes
- Your different customer types
- How cash moves through a club
Your AML/CTF team
Michael Anderson
Founder & Senior Legal Advisor
ACAMS Certified Anti-Money Laundering Specialist
With 28+ years advising registered clubs and hospitality groups, Michael Anderson leads Elite Legal's AML/CTF practice — from tailored risk assessments and programs to independent evaluations and AUSTRAC engagement. Trusted by boards across NSW and Queensland.
“Compliance shouldn't be a box-ticking exercise. Done properly, it protects your licence, your reputation and your community.”
In their words
Client testimonials
Michael is a master of his craft, his expert advice and flawless execution were invaluable to our much-loved community club throughout a demanding, at times emotional, amalgamation process. From the start, Michael was clear, patient, supportive and committed to ensuring our Board was fully informed and compliant at every step. His driven dedication throughout, and his exceptional performance at our general meeting, were critical to the comprehensively successful outcome.
Questions
Straight answers
Request an Independent Evaluation
Talk to us before AUSTRAC talks to you.
Send us your details and we'll be in touch about an Independent Evaluation — a confidential, no-obligation conversation about where your venue stands. Sydney, Brisbane, or at your venue.
Level 13, 111 Elizabeth St, Sydney
Level 10, 239 George St, Brisbane