For Registered Club CEOs, AML/CTF Compliance Officers and Board Members

AML/CTF Compliance for Registered Clubs involves more than updating a compliance document. With Australia’s revised Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework commencing on 1 April 2026, registered clubs should assess whether their updated AML/CTF Programs are being implemented effectively.

Effective AML/CTF Compliance for Registered Clubs requires clear procedures, appropriate staff training, regular risk assessments and accurate recordkeeping. Clubs must ensure their employees understand the revised requirements and consistently follow the controls established in their AML/CTF Programs.

As the 2026–2027 financial-year reporting period progresses, clubs should review their compliance arrangements, identify implementation gaps and ensure they maintain appropriate records of their activities.

The key question is simple: Has your club implemented the revised AML/CTF requirements in practice, or has it only updated its AML/CTF Program?

With AUSTRAC changing its annual compliance reporting arrangements to align with the financial year, Compliance Officers should also prepare for the next reporting cycle while managing their other responsibilities.

The next annual Compliance Report is expected to cover 1 July 2026 to 30 June 2027, with submissions due by 30 September 2027 under the applicable reporting arrangements.

Although the deadline may seem distant, now is the time to review your club’s implementation and address any gaps.

AML/CTF Compliance for Registered Clubs: Updating Your Program Is Only the First Step

Many registered clubs have invested considerable time reviewing and updating their AML/CTF Programs to reflect legislative changes.

However, updating a document is not the same as demonstrating that the revised requirements have been implemented.

Strong AML/CTF Compliance for Registered Clubs depends on effective implementation, clear responsibilities and regular reviews of compliance procedures.

Your club should now be able to demonstrate that:

• Risk assessments: The club’s money laundering, terrorism financing and applicable proliferation financing risks have been reviewed, with appropriate controls implemented.
• Customer due diligence: Customer identification and verification procedures reflect the applicable requirements, including those relevant to electronic gaming machine transactions.
• Staff training: Relevant employees have received appropriate AML/CTF training, and records demonstrate that training has been completed.
• Transaction monitoring: Transactions and unusual activity are monitored, assessed and escalated where necessary.
• Suspicious matter reporting: Relevant staff understand the internal escalation process and applicable suspicious matter reporting obligations.
• Governance and oversight: Senior management and the governing body receive appropriate information about the club’s AML/CTF compliance.
• Recordkeeping: Records and supporting evidence demonstrate how the club is meeting its obligations.

The important question is no longer simply whether your club has an AML/CTF Program.

Can your club demonstrate that its AML/CTF Program is being followed in practice?

Effective AML/CTF Compliance for Registered Clubs means being able to demonstrate that policies are translated into daily operations and that compliance responsibilities are understood across the organisation.

AUSTRAC Annual Compliance Reports: What Registered Clubs Need to Know

An important consideration for AML/CTF Compliance Officers is AUSTRAC’s move from calendar-year reporting to financial-year reporting.

Under the announced arrangements, the next reporting period is expected to cover 1 July 2026 to 30 June 2027.

Key reporting considerations include:

• Reporting period: 1 July to 30 June.
• Submission timeframe: Within three months after the reporting period ends, subject to the applicable reporting requirements.
• Annual reporting window: 1 July to 30 September.
• Next expected deadline: 30 September 2027.

The Compliance Report will cover the club’s AML/CTF activities during the relevant reporting period.

AUSTRAC is also updating its annual Compliance Report to reflect the revised AML/CTF framework. Clubs should consult the latest AUSTRAC guidance for the applicable reporting questions and submission requirements.

Maintaining effective AML/CTF Compliance for Registered Clubs also means keeping accurate records of compliance activities throughout the annual reporting period.

For registered clubs, this reporting responsibility may coincide with financial reporting, budgeting, audits and other end-of-financial-year activities.

For smaller clubs, where the CEO or Secretary Manager may also serve as the AML/CTF Compliance Officer, finding additional time to review records and prepare reports can be particularly challenging.

The best approach is to maintain compliance records throughout the year rather than attempting to reconstruct activities before the reporting deadline.

AML/CTF Compliance Checklist: What Should Your Club Review?

With the revised requirements in effect, registered clubs should assess whether their AML/CTF controls are operating as intended.

A regular review of AML/CTF Compliance for Registered Clubs can help identify gaps in staff training, customer due diligence, transaction monitoring and recordkeeping before they become more difficult to resolve.

Consider the following questions:

• Have relevant employees received training on the revised AML/CTF requirements?
• Are Duty Managers and gaming staff following the club’s customer identification and verification procedures?
• Are unusual transactions and suspicious behaviours being identified, assessed and escalated appropriately?
• Has the club reviewed its risk assessment and implemented the necessary controls?
• Are compliance activities documented and reported to management?
• Are customer due diligence and transaction monitoring procedures being followed consistently?
• Can the club provide evidence that its AML/CTF Program is being implemented in practice?

To strengthen AML/CTF Compliance for Registered Clubs, Compliance Officers should regularly assess whether staff are following established procedures and escalating concerns appropriately.

These questions are not simply about preparing for the next AUSTRAC Compliance Report. They are about ensuring that the club’s compliance arrangements remain effective.

Waiting until next year to identify implementation gaps could mean that important compliance activities have been overlooked for months.

Regular reviews help clubs identify weaknesses earlier and take corrective action before those gaps become more difficult to address.e difficult to resolve.

Make AML/CTF Compliance an Ongoing Management Activity

One of the challenges of AML/CTF Compliance for Registered Clubs is balancing regulatory responsibilities with the day-to-day demands of operating a venue.

For many Compliance Officers, AML/CTF is only one of several responsibilities competing for their attention.

A practical solution is to integrate AML/CTF compliance into the club’s regular management activities rather than treating it as an annual exercise.

Your club could establish a routine that includes:

• Reviewing AML/CTF compliance activities each month.
• Checking that relevant staff training remains current.
• Reviewing customer due diligence and transaction monitoring records.
• Identifying emerging risks and updating controls where necessary.
• Providing regular compliance updates to the CEO and governing body.
• Maintaining evidence of completed activities, identified issues and corrective actions.
• Preparing for annual reporting well before the submission deadline.

A consistent approach to AML/CTF Compliance for Registered Clubs helps management identify weaknesses early, document corrective actions and maintain evidence of ongoing compliance.

A structured approach throughout the year can reduce the administrative burden when it is time to complete the annual Compliance Report.

It also gives the CEO and Board greater assurance that the club is actively managing its AML/CTF obligations.

Don’t Wait Until Next Year to Review Your AML/CTF Program

The revised AML/CTF requirements are in effect, subject to any applicable transitional arrangements and specific commencement dates.

Although the next annual Compliance Report is expected to be due in September 2027, registered clubs should not delay reviewing their implementation.

Taking action now can improve AML/CTF Compliance for Registered Clubs by ensuring implementation gaps are identified and addressed before the next reporting deadline.

The longer an implementation gap remains unidentified, the harder it may be to demonstrate that the club has met its obligations.

Now is the opportunity to review what has been implemented, identify areas for improvement and establish a practical process for managing AML/CTF compliance for the remainder of the financial year.

Changes to annual reporting should not turn AML/CTF compliance into another last-minute task during an already demanding period.

With proper planning, regular reviews and strong recordkeeping, clubs can reduce administrative pressure while strengthening their compliance arrangements.

Need Help With AML/CTF Compliance for Your Registered Club?

At CHD Partners, we work with registered clubs to make AML/CTF compliance practical, manageable and easier to demonstrate.

CHD Partners can assist with AML/CTF Compliance for Registered Clubs, including program reviews, implementation support, staff training and ongoing compliance processes.

Whether you need assistance reviewing your revised AML/CTF Program, assessing implementation, supporting staff training or establishing an ongoing compliance process, we can help.

Our goal is to help your club understand its obligations, identify areas for improvement and develop a practical approach to ongoing compliance.

Don’t wait until next year to find out whether your AML/CTF Program is working.

Contact CHD Partners or send us a direct message to discuss how we can support your club’s AML/CTF compliance requirements.

Conclusion: Make AML/CTF Compliance for Registered Clubs a Priority

AML/CTF Compliance for Registered Clubs should be an ongoing priority, not a task reserved for the annual reporting period. As the revised AML/CTF framework takes effect, registered clubs need to ensure their compliance programs are implemented, monitored and reviewed regularly.

Effective AML/CTF Compliance for Registered Clubs requires more than updated policies. It involves staff training, risk assessments, customer due diligence, transaction monitoring, appropriate reporting procedures and reliable recordkeeping.

By taking a proactive approach to AML/CTF Compliance for Registered Clubs, CEOs, Compliance Officers and Board Members can identify implementation gaps, strengthen internal controls and maintain evidence of compliance activities throughout the financial year.

Clubs should also prepare for AUSTRAC’s annual Compliance Report by maintaining accurate records and reviewing compliance activities well before the submission deadline.

Ultimately, AML/CTF Compliance for Registered Clubs is about demonstrating that the club understands its obligations and has practical processes in place to meet them. Regular reviews and clear accountability can help make compliance more manageable while supporting stronger oversight.

Now is the time to assess your current AML/CTF Program, address any outstanding issues and establish a sustainable approach to ongoing compliance.

References 

• AUSTRAC – Annual Compliance Reports 
• AUSTRAC – AML/CTF reform guidance 
• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 

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