Personnel due diligence under AML/CTF is a critical compliance requirement for registered clubs in Australia under updated Anti-Money Laundering and Counter-Terrorism Financing obligations.
With regulatory changes effective from 1 April 2026, clubs must ensure that individuals operating gaming and financial systems are suitable, trustworthy and properly trained.
Personnel due diligence under AML/CTF is no longer just a human resources function. It is now a core component of an effective compliance and risk management framework.
For small to medium registered clubs, the challenge is understanding how personnel due diligence under AML/CTF applies in practice and how to implement a structured, risk-based approach.
Clubs do not need complex systems. However, they must maintain a documented and auditable process that demonstrates compliance if reviewed by AUSTRAC or an independent assessor.
What Is Personnel Due Diligence Under AML/CTF?
Personnel due diligence under AML/CTF refers to the process of assessing whether employees, contractors, managers, board members and other individuals involved in gaming or financial activities present a compliance risk to the organisation.
This includes determining whether a person:
- Is suitable for the role
- Understands AML/CTF obligations
- Can be trusted with financial or gaming systems
- Has appropriate system access
- May be exposed to corruption or coercion risks
- Has been properly screened and monitored
Personnel due diligence under AML/CTF should be integrated into the club’s broader compliance framework.
Why Personnel Due Diligence Under AML/CTF Is Important
Personnel due diligence under AML/CTF is essential because internal failures are a common source of compliance breaches.
Risks include:
- Staff collusion
- Weak supervision
- Poor training
- Failure to escalate suspicious activity
- Inappropriate system access
- Ignoring red flags
Regulators such as AUSTRAC expect clubs to demonstrate strong internal controls, including staff screening and oversight.
Which Personnel Should Be Assessed?
Not all roles carry the same AML/CTF risk.
High-Risk Roles
- Chief Executive Officers
- Secretary Managers
- Gaming Managers
- Duty Managers
- AML/CTF Compliance Officers
- Finance Managers
- Cashiers
- Staff handling cash payouts
- IT administrators with system access
- Contractors with gaming or financial access
These roles may have access to cash, customer data and reporting systems.
Low-Risk Roles
- Kitchen staff
- Cleaners
- Maintenance staff
- Grounds staff
Even low-risk roles should receive basic AML/CTF awareness training.
What Should Personnel Due Diligence Under AML/CTF Include?
The level of due diligence should be proportionate to the role and risk.
Identity Verification
The club should confirm workers’ identities before they commence employment.
This may include:
- Driver’s licence
- Passport
- Proof of right to work in Australia
- Contact details
- Residential address
Clubs should maintain records of verification consistent with privacy obligations.
Qualification and Licence Checks
Where relevant, clubs should verify:
- RSA competency
- RCG competency
- Security licences
- Financial or gaming qualifications
- Relevant experience
This helps ensure workers are appropriately skilled and legally permitted to perform their duties.
Reference Checks
Reference checks can help identify concerns such as:
- Previous dishonesty
- Failure to follow procedures
- Poor conduct around cash handling
- Integrity concerns
It is important to document that reference checks were completed.
Criminal History Considerations
Some clubs may choose to conduct criminal history checks for higher-risk positions.
This can be particularly relevant for personnel who:
- Handle cash
- Conduct customer due diligence
- Monitor transactions
- Approve payouts
- Access gaming systems
Clubs should ensure that any criminal history process complies with Australian privacy and discrimination laws.
Importantly, clubs should avoid a “tick box” approach. The key consideration is whether any history is relevant to the role and AML/CTF risk.
PEP and Sanctions Screening for Senior Roles
For some senior or sensitive positions, clubs may consider:
- Politically Exposed Person (PEP) checks
- DFAT sanctions screening
This is particularly relevant where individuals have influence over financial controls or decision-making.
The purpose is not to exclude people automatically, but to identify and manage potential risk appropriately.
AML/CTF Training
One of the biggest weaknesses identified in many clubs is assuming that staff “already know” what suspicious activity looks like.
Training should be:
- Role-specific
- Practical
- Conducted regularly
- Refreshed when legislation changes
- Supported by evidence and records
Examples
Bar and Gaming Staff
Should understand:
- Suspicious gaming behaviours
- Structuring
- Third-party cash use
- Minimal play cash-outs
- Customer reluctance to provide identification
Duty Managers
Should understand:
- Escalation obligations
- Internal reporting processes
- When to involve the AML/CTF Compliance Officer
Board Members
Should understand:
- Oversight responsibilities
- Governance obligations
- Risk reporting expectations
Ongoing Monitoring of Personnel
Personnel due diligence is not a “once-only” activity.
Clubs should monitor for:
- Unusual staff behaviour
- Failure to follow procedures
- Unexplained overrides
- Repeated breaches
- Excessive relationships with patrons
- Failure to escalate suspicious matters
Examples may include:
- A staff member is repeatedly processing payouts without proper identification
- A manager discouraging staff from escalating suspicious behaviour
- Cash handling inconsistencies
- Staff sharing passwords or access credentials
Risk-Based Approach to Personnel Due Diligence Under AML/CTF
Every Club is different, so it is critical to take a practical approach to classify positions and risk, for example:
Risk Level: Low — Example Roles: Cleaner, maintenance — Suggested Controls: Basic AML/CTF awareness
Risk Level: Medium — Example Roles: Bar staff, supervisors — Suggested Controls: Training, ID verification, supervision
Risk Level: High — Example Roles: Gaming manager, cashier, compliance officer — Suggested Controls: Enhanced screening, references, targeted AML/CTF training, periodic review
This allows clubs to apply resources proportionately rather than treating every role identically.
Importance of Evidence
One of the major lessons emerging from recent AML/CTF reviews is that many clubs believe they are compliant but cannot quickly produce evidence.
If AUSTRAC or an independent reviewer asks for evidence, clubs should be able to demonstrate:
- Personnel screening records
- Position risk assessments
- AML/CTF training records
- Refresher training
- Role descriptions
- Access permissions
- Escalation records
- Supervisory checks
If evidence takes weeks to gather, this may indicate the system is not functioning effectively.
Practical Steps for Small to Medium Clubs
Small clubs do not need overly complex corporate systems. However, they should implement practical controls such as:
- Maintaining a personnel due diligence checklist
- Defining high-risk positions
- Conducting role-based AML/CTF training
- Maintaining training registers
- Recording reference checks
- Monitoring access to gaming and customer systems
- Reviewing personnel risks annually
- Reporting AML/CTF personnel risks to the board
Even simple documented processes are significantly better than undocumented assumptions.
Role of the Board and Senior Management
Boards should not assume AML/CTF is “handled by the compliance officer.”
The board should receive periodic reporting on:
- AML/CTF training completion
- High-risk personnel positions
- Personnel breaches or concerns
- Internal investigations
- Staff non-compliance trends
- Review outcomes
Directors should be able to demonstrate reasonable oversight of the club’s AML/CTF control environment.
Conclusion
Personnel due diligence under AML/CTF is essential for protecting clubs, staff and the broader community.
An effective AML/CTF program ensures that individuals operating within clubs are properly screened, trained and monitored. Personnel due diligence under AML/CTF must be treated as a continuous process, not a one-time HR activity.
Clubs that implement strong personnel due diligence under AML/CTF frameworks are better positioned to meet regulatory expectations, reduce compliance risk and demonstrate accountability to regulators.
It is also important that personnel due diligence under AML/CTF is supported by clear documentation, ongoing monitoring and regular staff training to ensure long-term effectiveness.
When personnel due diligence under AML/CTF is embedded into everyday operations, clubs can significantly reduce exposure to financial crime risks and improve overall governance.
For small and medium registered clubs, prioritising personnel due diligence under AML/CTF is one of the most practical and effective steps toward strengthening AML/CTF compliance.
For support implementing or improving your compliance framework, contact CHD Partners Contact Us for expert AML/CTF guidance and training solutions.
External Resources
For official guidance, refer to AUSTRAC and Australian Government AML/CTF resources.
