While companies that provide gambling services have been reporting large cash payments to AUSTRAC for several years, new cash transaction rules that could be introduced in 2021 will penalise all businesses if they make or accept cash payments greater than $10,000 amid a federal government crackdown on lost tax revenue.

Treasury has also outlined tighter requirements for companies governed by Australia’s anti-money laundering laws, who currently report large cash payments to AUSTRAC, which will include Clubs, hotels and casino businesses.

The cash transaction limit will be extended and imposed for payments for goods and services to all entities holding an Australian Business Number (ABN).

An outline of how the cash payment limit will work is provided by Treasury (see source below) and raises some interesting questions for venues supplying gaming services if a “single supply of goods or services” is taken to mean the accumulated use of gaming machines, and over what period “single supply” is defined:

  • The cash payment limit will apply to the total price of a single supply of goods or services, regardless of whether the price is split into a series of payments over time.
  • The total cash payments made towards the final price paid must not be equal to or exceed $10,000. The remainder of the payments must be made electronically or by cheque.

In any event, this will certainly be an administrative change for many current club, hotel and casino guests who own businesses