The 2026 AML/CTF Shake-up: What NSW & QLD Venues Need to Do
New federal laws are changing how you handle gaming and compliance.
Most of these kick in on 31 March 2026.
What do you need to do to be compliant?
1. The $5,000 ID Threshold
The Law: The federal threshold for verifying patron identity during gaming payouts is dropping from $10,000 to $5,000.
The Change: While you already ID patrons at $5,000 for state-based EFT/cheque payout rules, this is now a mandatory AUSTRAC requirement.
Action: Update your AML/CTF Program and staff procedures to ensure all payouts of $5,000 or more are recorded for federal compliance, not just state gaming records.
2. Simplified Compliance Programs
The Law: The requirement to maintain a "Part A" (Risk) and "Part B" (ID) program is being removed.
The Change: Venues must now maintain a single, integrated AML/CTF Program.
Action: Transition your existing documentation into one streamlined manual that reflects your venue’s specific operations before the March 2026 deadline.
3. Board and Management Accountability
The Law: Federal law now explicitly requires a venue’s "Governing Body" (Boards or Owners) to have direct oversight of the AML/CTF Program.
The Change: Compliance is no longer the sole responsibility of the AML/CTF Compliance Officer; it starts at the top.
Action: Ensure your Board or owners formally review and approve the AML/CTF Program and receive regular updates on its effectiveness.
4. Proliferation Financing Risk
The Law: All reporting entities must now include "Proliferation Financing" (risks associated with the financing of weapons of mass destruction) in their risk assessments.
The Change: This is a new mandatory risk category for all Australian venues.
Action: Document a specific assessment of this risk within your written AML/CTF risk assessment.
5. AUSTRAC Reporting & Registration
The Law: New rules regarding the appointment and notification of AML/CTF Compliance Officers.
The Change: Reporting entities must notify AUSTRAC of their Compliance Officer’s details and any subsequent changes.
Action: Ensure your venue’s details are up to date on the AUSTRAC portal and notify them of your designated officer by 30 May 2026.
The Bottom Line for 31 March 2026
The new AUSTRAC reforms shift the focus from a "checkbox" exercise to a risk-driven, outcomes-based model. For gaming venues, the message is clear: compliance starts with leadership and ends with accurate, documented action.
Audit Your Current Program: Use the remaining weeks to bridge the gap between your current state-based ID habits and your new federal obligations.
Document Everything: If you cannot fully implement every change by the deadline, AUSTRAC expects a documented Implementation Plan detailing how you will manage risks during the transition.
Empower Your Board (or Owners): If you are a private owner, you are the board. Under the new laws, "oversight" isn’t just a corporate buzzword, it’s a personal legal obligation. The board, or owner, must review and sign off the program.
This information should be read in conjunction with, and not as a substitute for, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and the AML/CTF Rules. We do not guarantee the accuracy or completeness of the material and accept no legal liability arising from or connected to the use of or reliance on any information contained herein.
Before making any decisions or taking action based on this content, you should seek independent professional advice tailored to your specific circumstances."