AMLCTF Compliance in Clubs is a critical requirement for Australian registered clubs, especially those operating gaming machines or other regulated services. Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AMLCTF Act), clubs must not only “know their customer,” but also “know their staff.” This includes proper reference checks, background screening, and ongoing re-screening to meet AUSTRAC expectations.

Understanding AMLCTF Compliance in Clubs 

Australian clubs that qualify as reporting entities must maintain a written AMLCTF Program (Part A), which includes a risk-based Employee Due Diligence (EDD) component. Effective AMLCTF Compliance in Clubs means having procedures that screen staff at hiring and at key points during employment.

AUSTRAC’s guidance for pubs and clubs clearly expects reporting entities to:

1. Screen New Hires in Sensitive Roles (AMLCTF Compliance Requirement)

Before employing anyone in a position that could facilitate money laundering or terrorism financing, conduct detailed background checks. This ensures new hires meet probity requirements and are who they claim to be—an essential part of AMLCTF Compliance in Clubs.

2. Re-Screen Before Promotions or Transfers

Under AMLCTF Compliance in Clubs, you must not rely on an employee’s past suitability. Any staff member moving into a role with higher AML/CTF exposure must undergo updated screening. AUSTRAC explicitly requires renewed vetting before occupying a role that could enable ML/TF activity.

Failing to meet these obligations exposes the club to regulatory breaches, penalties, and increased operational risk. With AUSTRAC intensifying its scrutiny of clubs, robust AMLCTF Compliance in Clubs is essential—not optional.

What Screening Should Include for AMLCTF Compliance in Clubs

An effective employee due diligence program goes beyond a basic interview. AUSTRAC expects screening processes to be thorough and well-documented. Strong AMLCTF Compliance in Clubs includes:

• Identity verification: Confirm the person’s identity and legal right to work. 
• Employment history & qualifications: Validate the candidate’s resume by checking their employment records and certifications – for example, by contacting previous employers or referees for references. (In practice, ensure that all past roles and claims are verified. One industry best practice is to contact former employers to confirm the person’s experience and document those checks on the employee’s file.) 
• Character and integrity checks: Conduct background checks to assess the individual’s past conduct. This can include a National Police Check for criminal history, and if relevant, a credit history or bankruptcy check for any financial red flags. 
• Licensing or regulatory clearance: If the role requires a specific licence or approval (for example, a state gaming machine licence that involves a fit-and-proper person test), verify that the person holds a valid licence in good standing. Any disciplinary actions or regulatory issues should be factored into your decision. 
• Overall risk assessment: Finally, consider whether the person is suitable for the position and if they pose any risk to your business. For higher-risk roles (e.g. those handling large cash transactions or compliance oversight), you might apply extra scrutiny – checking for criminal associations, any legal or regulatory actions against them, or if they have lived in high-risk jurisdictions, etc. 

All findings from these checks should be documented. This documentation not only demonstrates compliance if AUSTRAC comes knocking, but it also protects your organisation by creating an audit trail of due diligence. 

Re‑Screening: Not “Set and Forget” 

Initial screening is only part of the story. Re‑screening employees is a must when circumstances change. Promotions, role changes, or expansions of duty can elevate an employee’s risk profile – and your controls must keep up. For example, if a staff member moves from a general hospitality role into a finance manager or compliance officer position, you should treat it almost like a new hire in terms of due diligence. This could uncover issues that were not apparent (or not relevant) in their previous role. 

Beyond role changes, consider periodic re-checks of staff even if they stay in the same position. AUSTRAC suggests it is best practice to rescreen employees at regular, risk-based intervals. Some organisations ask staff to self-attest every few years that their circumstances haven’t materially changed (for instance, no new criminal charges, no significant financial troubles), coupled with updates to police checks as needed. While the frequency and depth of re-screening should align with your club’s risk profile, the key is to ensure that an employee’s ongoing suitability is not assumed but actively confirmed. 

Knowing your customer is vital – but knowing your staff is equally non-negotiable.  

References: 

• AUSTRAC, Pubs and Clubs Sector AML/CTF Guide – Employee due diligence requirements austrac.gov.au 
• AUSTRAC, Core Guidance on AML/CTF Programs – Part A (Employee due diligence) austrac.gov.auaustrac.gov.au 
• CHD Partners, Independent Reviews for Registered Clubs – Importance of screening & reference checks chdpartners.com.auchdpartners.com.au 
• AUSTRAC, Employee Due Diligence Guidance – Screening processes and best practices austrac.gov.au