Tranche 1 · Pubs & Clubs
AML compliance for pubs and clubs with gaming machines
Pubs and clubs operating electronic gaming machines have long-standing AUSTRAC obligations. Trancher supports practical customer due diligence, monitoring, reporting and record-keeping that fit the realities of venue-based gaming.
Am I captured?
Pubs and clubs licensed to operate electronic gaming machines can be reporting entities when they provide designated gambling services.
The test is the service you provide — not simply whether you operate a pub or club.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. Cash intensity and high transaction volume are the risk. Know the customer at the threshold that applies to your venue or channel, watch for structuring, and report suspicions without tipping the patron.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your pub or club could be used for money laundering or terrorism financing — customers, gaming activity, cash exposure, venues or channels and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how your pub or club will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Customer due diligence, ongoing monitoring and reporting built around gaming activity, higher-risk customers and the realities of venue-based operations.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your operation — use Trancher within your existing AML/CTF operations, add expert support where needed, or have agreed activities managed for you.
1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with implementation, risk assessment, program updates, onboarding, training or operational reviews.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
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View article →Questions from pubs and clubs
Am I captured?
Pubs and clubs with electronic gaming machines can be reporting entities when they provide designated gambling services. Obligations depend on the specific services provided, not simply on operating a pub or club.
What are the deadlines?
Tranche 1 obligations have applied for years. The focus is ongoing compliance with the updated regime rather than a new Tranche 2 commencement deadline.
What goes in the program?
Your AML/CTF program must include a risk assessment of the gaming activity and the controls used to manage money laundering and terrorism financing risk — including customer due diligence where required, higher-risk customer controls, monitoring, suspicious matter reporting, staff training and record-keeping.
What does CDD look like in practice?
Apply customer due diligence as required by your designated services and risk assessment. Identify and verify customers where required, screen for PEPs, sanctions and adverse media, and apply enhanced due diligence when risk is higher. Keep records that demonstrate what was checked and why.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity — for example directors, beneficial owners or authorised persons — each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.