Anti-Money Laundering for Pubs and Clubs Course (Australia)

Understanding your obligations under the new laws

Across NSW, $95 billion was turned over in electronic gaming machines in pubs and clubs in the 2020-2021 financial year. The NSW Crime Commission found that a ‘significant amount’ of the money which is put through these machines is the proceeds of crime, or ‘dirty money’. To combat this, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 places significant anti-money laundering obligations on persons who operate pubs and clubs. Very heavy penalties apply for breaches of the Act.

To help pubs and clubs and their employees comply with these responsibilities, this course, comprising four short modules, outlines the requirements and the actions that needs to be taken.

Module one describes how money laundering and terrorism financing work, so that learners will be better able to recognise the danger signs. It goes on to set out the responsibilities individuals
have under the AML/CTF regime. By providing scenarios and examples of money laundering modalities, it prepares pubs and clubs staff to assess the ML/TF risks posed by their patrons.

Modules two and three outline a number of the AML/CTF obligations for pubs and clubs. They set out the requirement that each business must have an AML/CTF Program and supporting policies, and what those must contain. They give guidance on completing an AML/CTF risk assessment and the main money laundering and terrorism financing risks pubs and clubs face. The modules also set out essential Know Your Customer and Customer Due Diligence practices and ways of managing the burden of complying with AML/CTF obligations

Module four goes into detail on the reporting requirements for pubs and clubs as well as the record keeping requirements set out in the Act.

Laundering money through local clubs or hotels makes up a sizeable proportion of the estimated $20 billion in criminal proceeds laundered in NSW each year.
– Charles Livingstone, Associate Professor, School of Public Health, Monash University