GETTING READY FOR UPCOMING AUSTRAC REGULATORY REFORMS – WHAT YOU NEED TO KNOW

Important changes that are coming through from the Australian regulator AUSTRAC affect how Pubs and Clubs manage anti-money-laundering / counter-terrorism-financing (AML/CTF) obligations.

What has changed

Last year, AUSTRAC released updated regulatory guidance (and accompanying priorities) to reflect the forthcoming law-reform under the Anti‑Money‑Laundering and Counter‑Terrorism Financing Act 2006 (AML/CTF Act) and its associated Rules. Key elements include:

1. Stronger emphasis on risk-based outcomes – The regulator is making clear that merely ticking boxes won’t suffice. AUSTRAC expects businesses to adopt proportional, outcome-oriented AML/CTF programs rooted in actual money-laundering, terrorism-financing or proliferation-financing risks (ML/TF/PF).
2. Upcoming reforms for current reporting entities – Businesses already regulated must prepare for changes effective from 31 March 2026, including revised AML/CTF program requirements (stronger CDD, revised reporting obligations, “must do” activity assessment and reporting)
3. Focus on newly regulated sectors (Tranche 2) – From 1 July 2026, many new industry segments (legal, accounting, real estate, precious metal/stone dealers) will fall within the regime. Even though that may not apply to the hospitality industry now, it signals the regulatory direction.
4. Enhanced reporting obligations & data quality – The regulator is zeroing in on the quality (not just quantity) of Suspicious Matter Reports (SMRs) and other transaction data.

What’s different compared to the previous guide

While the previous guidance emphasized foundational compliance (programs, CDD, reporting under the existing AML/CTF Act), the October 2025 version (and related materials) indicates a shift in several ways:

• The earlier version was more compliance-process focused (i.e., “do you have an AML/CTF program?”, “have you done CDD?”, “are you reporting?”). The new version moves further into “is the program effective?”, “does it reflect actual risk?”, and “how are you managing emerging risks?”
• Previously, many obligations (for current entities) were stable; now major reform is being flagged with clear instruction of what you MUST HAVE rather than SHOULD DO. MUST HAVE in this sense is a legal requirement.
• The definition and expectations of risk are highlighted, and venues must be aware of all risks even when simple changes occur like buying new EGM’s or a change in demographics, it’s up to the venue to keep the risk assessment updated and documented.
• In earlier guides, the focus was largely on “compliance with the Act and Rules as they stand”. The updated version emphasizes risk and activity and responsibilities and the need for current entities to be forward-looking.
• P16 of the guide outlines it is The Board and Senior Execs who are ultimately responsible for assessing the risks and setting the rules and monitoring compliance.
• Monitoring transactions, even in uncarded play, is expected.
• Exception reporting and independent audits will be expected, and the ease in which venues can provide the information will be considered.

Why this matters and how software like PaySafeGo and Consultants help

As a provider of payment and value transfer services, gaming venues are operating in a high-risk environment where regulatory expectations are evolving quickly. Here’s why these matters, and how PaySafeGo is positioned to support you:

• Risk-based program alignment: The new AUSTRAC guidance demands more than a static compliance checklist. With Paysafego’s platform and services, we help you embed AML / CTF controls that are automated and embedded in your rules and aligned to real business risk (rather than just standard box-ticking).
• Investment in futureproofing: With reforms coming into effect March 2026 and July 2026, early preparation is key. PaySafeGo’s systems and workflows are designed to adapt to upcoming rule changes (e.g., value transfer chain messaging, enhanced CDD).
• Applying Risk Assessment into Actionable compliance, Guidance for all staff to help them keep within the rules as set by the venue.
• Quality of reporting & data: Since AUSTRAC is increasingly focused on reporting quality, using tools, such as PaySafeGo, ensures your transaction flows, documentation and audit trails are captured in structured, compliant formats — helping avoid further regulatory scrutiny. All automated to minimize workload on existing teams.
• Tailored guidance and support: Companies like PaySafeGo proactively review the AUSTRAC updates and provide venues with guidance and tools to interpret the changed obligations in plain language.
• Competitive advantage: By staying ahead of reform, venues can position their business not only to comply but to demonstrate to partners, counterparties and regulators that they are operating with strong AML/CTF controls — enhancing trust and market-credibility.

What’s Next

• If you haven’t done so already, read the “Pubs and Clubs with Gaming Machines Regulatory Guide”.
• Review your current AML/CTF program now against the updated AUSTRAC expectations. First point: Does the venue have a documented plan, especially risk assessment.
• Consider how the venue’s processes (customer onboarding, monitoring, reporting) will need to evolve considering the 2026 reforms.
• Engage with a Consultant or Independent Auditor to review the existing processes and map out the venue’s plan for 2026.
• Stay informed: AUSTRAC is publishing further guidance, timelines, and sector-specific alerts into 2026.

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