AUSTRAC Tranche 2 Is Here: What Happens After March
31 March 2026 marked the start of Australia’s updated AML/CTF regime for gaming venues.
For many pubs and clubs, it felt like a deadline. In reality, it was a transition point.
From here, AUSTRAC’s focus is less on whether documents exist, and more on whether AML/CTF obligations are being applied consistently in day‑to‑day operations.
What’s changed
AML/CTF is no longer an implementation project.
It’s now assessed as an ongoing operational discipline.
After March, venues should be able to show:
How risks are identified and reassessed
How staff apply controls at the point of play
How governance and oversight operate in practice
How issues are identified, escalated and addressed
This applies to all gaming venues, regardless of size.
This applies to all gaming venues
There has been understandable confusion around thresholds and who the reforms apply to.
To be clear:
All gaming venues are captured by the updated AML/CTF framework
Some obligations increase once a venue operates 16 or more gaming machines
But core requirements apply across the sector
One critical example is customer identification.
The $5,000 threshold applies to everyone
From 31 March 2026, all gaming venues must conduct Customer Due Diligence once a customer’s gambling activity reaches $5,000.
There is no transition period for this requirement.
Venues must show that gaming staff understand this trigger, and apply it consistently.
Where the 16‑machine threshold still matters
While Tranche 2 applies to all gaming venues, venues operating 16 or more gaming machines are subject to additional expectations, including:
Formal reporting obligations
More detailed AML/CTF program and governance requirements
Increased regulatory scrutiny
This reflects AUSTRAC’s risk‑based approach to gaming environments.
What AUSTRAC is focused on now
Post‑March, AUSTRAC’s messaging has been consistent.
They are looking beyond:
Whether policies exist
Whether advisers have been engaged
And focusing on:
Whether risk assessments reflect how venues actually operate
Whether staff know what to do and when
Whether boards and committees are actively involved
Whether venues can explain and evidence their decisions
Generic or template‑based programs that aren’t tailored to the venue remain a key risk area. One size fits all will not work.
A common red flag is where a group operates multiple hotels in different locations but applies the same risk assessment across every venue.
Even within the same group, a regional pub, a suburban hotel and a CBD venue will face very different risks. When those differences aren’t reflected in the assessment, it’s a clear sign the program hasn’t been properly tailored.
Your AML/CTF documentation should reflect reality. Perfection isn’t the expectation, but it must be a living document, shaped by real operations and ongoing input across the venue.
At Admyn, we’re building hospitality‑focused AML/CTF tools to support venues beyond the initial reform period.
We’ll share more shortly. Follow along, or get in touch if you’d like to talk through what comes next.