Pubs, clubs and hotels
Hotels, pubs, and licensed clubs that provide certain gambling or payment services become reporting entities under Tranche 2 reforms effective 1 July 2026.
AML/CTF Amendment Act 2024 — Tranche 2 Reform
AML/CTF Obligations
Enrol with AUSTRAC before 1 July 2026 if providing designated gambling or payment services
Conduct an ML/TF Risk Assessment and implement a written AML/CTF program
Conduct CDD on customers engaging in transactions above prescribed thresholds
Lodge SMR reports within 3 business days of forming a suspicion
Lodge TTR reports within 10 business days of a cash transaction at or above $10,000 AUD
Maintain all CDD and transaction records for a minimum of 7 years
Licensed venues must lodge TTR reports within 10 business days of a cash transaction at or above $10,000 AUD. SMR reports must be lodged within 3 business days of forming a suspicion about a customer or transaction.
Typical Customer Risk Profiles
Regular large-cash gaming machine players — customers who consistently load high amounts of cash into gaming machines, particularly if they collect winnings by cheque, are exhibiting classic placement behaviour.
Customers using third-party funds for gaming — someone who accepts cash from another person before using gaming facilities is almost certainly a smurfing participant and should trigger immediate investigation.
High-frequency cash transactions just below reporting thresholds — a customer who consistently transacts just under $10,000 at your venue is likely structuring to avoid TTR obligations.
Customers with no apparent legitimate income for the volume of gambling — a customer whose declared or apparent income is inconsistent with their gambling expenditure requires a source of funds inquiry.
Recommended Compliance Pack
Pubs & Clubs Pack
Pre-configured for Pubs, clubs and hotels — KYC rules, risk thresholds, AUSTRAC report templates, CDD workflows, and monitoring rules aligned to your obligations. Ready from day one.
View pack detailsWhat's included
System default — customisableCustomer identification and KYC workflows calibrated for gaming and venue transaction thresholds
TTR report templates pre-populated from transaction data with AUSTRAC validation
Structuring detection and gaming pattern alerts for high-risk customer activity
SMR case management for MLRO review and AUSTRAC lodgement
AML/CTF program template for licensed venues with staff training tracking and risk assessment
Example workflow
Default — you can modify stepsCustomer presents at gaming area
Cash load at or above threshold? CDD triggered. Digital ID check sent or processed on-site.
Identity verified
Photo ID captured. Sanctions and PEP screening runs automatically.
Gaming pattern recorded
Transaction added to customer's monitoring profile. Amount, frequency, and payout method tracked.
Structuring check
Customer's prior transactions reviewed. Multiple loads near $10,000? Alert raised for venue MLRO.
TTR generated if applicable
Cash transaction at or above $10,000? TTR auto-populated and queued for review.
TTR submitted or SMR filed
TTR submitted within 10 days. Suspicious pattern identified? SMR prepared and filed within 3 days.
Pricing Recommendation
Recommended
Essential
Most licensed venues need threshold-triggered KYC, TTR generation, and SMR capability. The Essential plan covers all core Tranche 2 obligations for pubs, clubs, and hotels.
View full pricingReady to get compliant as a Pubs & Clubs?
Your Pubs & Clubs Pack is configured on day one. 7-day free trial — no credit card, no consultants, no configuration sprints.