I have been asked this question several times over the last few weeks.
For many small to medium licensed venues (registered clubs and hotels), it is common to ask whether one person can perform multiple roles – specifically, whether the AML/CTF Compliance Officer can also act as the Gaming Manager.
The short answer is yes, this can occur, and in many situations, there are limited options due to the size of the venue.
However, it comes with clear risks and expectations that must be managed to meet obligations under the AMLCTF framework and relevant state-based gaming legislation.
What the Law and Guidance Say
Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, reporting entities (including clubs that operate EGMs) must appoint a Compliance Officer to oversee the AML/CTF program.
AUSTRAC guidance does not prohibit the Compliance Officer from holding another role, such as Gaming Manager. However, it does clearly state:
- The Compliance Officer must have appropriate authority, independence, and access to information
- They must be able to challenge decisions and escalate issues without conflict
- They must ensure ongoing compliance, monitoring, and reporting
This is where the risk sits when combining roles.
Understanding the Two Roles
AML/CTF Compliance Officer – Core Responsibilities
The Compliance Officer is responsible for:
- Developing and maintaining the AML/CTF program
- Ensuring customer due diligence (CDD, OCDD, ECDD) is completed
- Overseeing transaction monitoring and suspicious matter reporting (SMRs)
- Reporting to senior management and the Board
- Liaising with AUSTRAC
- Ensuring staff are trained and aware of obligations
This role is governance, oversight, and assurance-focused.
Gaming Manager – Core Responsibilities
The Gaming Manager is responsible for:
- Day-to-day operation of electronic gaming machines (EGMs)
- Compliance with state legislation (e.g. NSW gaming regulations)
- Managing payouts, machine operations, and staff
- Ensuring responsible gambling practices
- Handling customer interactions and incidents
This role is operational and customer-focused.
Where the Conflict Can Occur
Combining the roles creates a “marking your own homework” risk.
Example 1 – Customer Due Diligence
A Gaming Manager processes a $5,000+ payout and completes identification.
As Compliance Officer, they are also responsible for:
- Reviewing whether that identification was sufficient
- Determining if the behaviour is suspicious
There is a risk that they may not objectively challenge their own decision.
Example 2 – Suspicious Matter Reporting (SMR)
A patron shows structured play behaviour.
- Gaming Manager: wants to maintain customer experience
- Compliance Officer: must consider submitting an SMR
There is a commercial vs compliance conversation.
Example 3 – Transaction Monitoring
Gaming Managers often rely on system reports (e.g., carded play reports and payouts).
Compliance Officers must:
- Independently review patterns
- Question whether monitoring is effective
If roles are combined, the independent review can weaken.
When Combining Roles Can Work
For smaller venues, combining roles can be acceptable if controls are in place.
Practical Control Measures
Clear Role Separation (Even if Same Person)
Be clear when the person is acting as:
- Gaming Manager (operations)
- Compliance Officer (oversight)
Example:
A monthly AML/CTF review meeting where the individual formally switches roles and documents findings for each area.
Secondary Oversight
Involve:
- CEO / General Manager
- Finance Manager
- Board or Audit Committee
Example:
All SMR decisions or high-risk customers are reviewed by a second person.
Strong Reporting Framework
Regular reporting to the Board, including:
- High-risk customers
- Transaction monitoring outcomes
- SMRs submitted
- Training completion
Use of Systems (e.g. CIRT, EGM reports)
- Automate tracking where possible
- Ensure reports are reviewed, not just generated
Simple Test for Your Venue
Ask the following:
- Can the Compliance Officer objectively review gaming decisions?
- Is there someone else reviewing high-risk decisions?
- Is AML/CTF given enough time and priority?
- Is the person performing these duties clear about the different responsibilities?
If the answer is “no” to any of the above, separation or additional controls are required.
Key Takeaway for Venue Operators
Combining the Compliance Officer and Gaming Manager roles is not prohibited, but it is high-risk if not managed properly.
But it doesn’t mean it can’t be.
The key is understanding this:
- The Gaming Manager runs the floor.
- The Compliance Officer questions what happens on the floor.
If one person is doing both, your system must ensure they can step back, challenge decisions, and demonstrate good decision-making.
#CHDPartners #CIRT #RTO #WHS #AMLCTF #GamingCompliance #WorkHealthAndSafety #Training #RiskManagement #SecurityAndSafetyCompliance #SME #SmallBusiness #MichaelHuggett