AML/CTF update: If your registered club operates gaming machines, a critical compliance change took effect on 1 April 2026 that requires immediate action.
These new requirements remove previous identification exemptions and introduce stricter expectations for customer verification, staff training, and transaction monitoring.
AML/CTF Update: Key Changes for Gaming Machines
Under the new rules:
- The $10,000 identification exemption has been removed
- Customer identification is now required at $5,000
- Cash redemption terminals must be set below $4,999.95
These changes significantly lower the threshold for identification and increase the responsibility on clubs to monitor transactions closely.
Compliance Requirements for Clubs
As part of this regulatory change, your club must now ensure:
- Customers are identified and verified once transactions reach $5,000
- Staff understand and apply Customer Due Diligence (CDD)
- Your AML/CTF program is updated to reflect the new rules
- Your transaction monitoring systems align with the updated threshold
Failure to align your processes with these requirements may result in serious compliance risks.
Why This AML/CTF Update Matters
This AML/CTF update strengthens Australia’s regulatory framework under AUSTRAC and is designed to reduce:
- Money laundering through gaming machines
- Structuring transactions to avoid detection
- Anonymous cash movement within venues
If these rules are not applied consistently, your club may face regulatory penalties, audits, or enforcement action.
Practical Steps to Stay Compliant
To meet these updated obligations, you should:
- Review and update your Customer Due Diligence procedures
- Train all gaming and cash-handling staff immediately
- Ensure supervisors are actively monitoring compliance
- Align your systems, including CIRT training and monthly compliance tasks
This is not just a policy change—it requires real operational adjustments across your team.
Common Mistakes Clubs Should Avoid
Many clubs may unintentionally fall short by:
- Failing to identify customers at the $5,000 threshold
- Not recognising aggregated transactions
- Providing insufficient staff training
- Not updating internal AML/CTF procedures
Avoiding these issues is critical to maintaining compliance.
Staff Training Prompt (Toolbox Talk)
Use this AML/CTF update scenario with your team:
If a member or patron reaches $5,000 in gaming machine transactions, what do you do?
Your team should confidently explain:
- When identification is required
- What documents are acceptable
- Who to escalate to if unsure
FAQ: AML/CTF Requirements for Registered Clubs
What is the AML/CTF update for gaming machines?
This AML/CTF update lowers the identification threshold to $5,000 and removes the previous $10,000 exemption.
Who enforces these requirements?
This AML/CTF update is enforced by AUSTRAC, Australia’s financial intelligence and regulatory authority.
What happens if a club fails to comply?
Failure to comply with this AML/CTF update may result in penalties, regulatory action, or audits.
Need Help Implementing These Changes?
If you need support applying this AML/CTF update, we can help you:
- Update your AML/CTF procedures
- Train your staff effectively
- Implement compliance through your CIRT system
👉 Contact us today to ensure your club remains compliant and protected: https://www.chdpartners.com.au/contact-us/
