COMPLIANCE LAW FIRM
Specialising in advising the gambling sector on government regulation including Anti-Money Laundering and Counter-Terrorism Financing and AUSTRAC compliance
Online AML/CTF training for gaming venues:
services
REGULATORY ADVICE
Legal advice on AUSTRAC government regulation for Hotels, Pubs and Clubs and Casinos.
NEW AML/CTF POLICY TOOLKIT
Designed for use with AML/CTF Reform to set out the compliance program for the gaming venue or casino
AML/CTF INDEPENDENT EVALUATIONS
Independent Evaluation of your gaming venue’s AML/CTF compliance (from 2027)
AML/CTF TRAINING
Gaming staff training and Board/Committee strategy for AML/CTF compliance, including on-demand online training and webinars.
AUSTRAC ENGAGEMENT & EXEMPTIONS
Engagement with regulators on behalf of your business, including regarding compliance issues or to seek an exemption.
COMPLIANCE REPORTING ADVICE
Legal advice on the annual compliance report to AUSTRAC.
services
REGULATORY ADVICE
Legal advice on AUSTRAC government regulation for Hotels, Pubs and Clubs and Casinos.
NEW AML/CTF POLICY TOOLKIT
Designed for use with AML/CTF Reform to set out the compliance program for the gaming venue or casino.
AML/CTF INDEPENDENT EVALUATIONS
Independent Evaluation of your gaming venue’s AML/CTF compliance (from 2027).
AML/CTF TRAINING
Gaming staff training and Board/Committee strategy for AML/CTF compliance, including on-demand online training and webinars.
AUSTRAC ENGAGEMENT & EXEMPTIONS
Engagement with regulators on behalf of your business, including regarding compliance issues or to seek an exemption.
COMPLIANCE REPORTING ADVICE
Legal advice on the annual compliance report to AUSTRAC.
ABOUT GOVLAW
GOVLAW focuses on providing legal advice for gaming venues and casinos in federal government regulation for anti-money laundering and counter-terrorism financing (AML/CTF) laws.
Our principal lawyer has over ten years experience working at AUSTRAC, where he was the lead drafter on three Chapters of the original AML/CTF Rules.
In 2020, GOVLAW’s submission against proposed changes to the AML/CTF Rules was picked up by the media (link here) and with support from industry, succeeded in convincing AUSTRAC to discontinue the amendments.
GOVLAW has also made submissions to federal parliamentary enquiries on Australian AML/CTF law and was quoted in Senate Committee reports in both 2022 (link here – see, pages 46, 51 and 67) and 2024 (link here – see, page 73).
In 2025, our principal presented on new legislative powers for AUSTRAC at the Commonwealth Association of Legislative Counsel Drafting Conference in Perth (link here).
We are passionate about communicating in plain language about what can often be complex regulatory environments.
AML/CTF legal advice - for Hotels, Clubs, Pubs and Casinos
In mid-2025, AUSTRAC launched Federal Court civil penalty proceedings against Mount Pritchard District and Community Club (‘Mounties’), for alleged serious and systemic non-compliance with AML/CTF laws.
In May 2026, AUSTRAC ordered the Bankstown District Sports Club Ltd to appoint an external auditor at the Club’s expense, amid concerns its AML/CTF controls may not be strong enough to stop organised crime exploiting poker machines and gambling venues (link here).
Is your venue gambling with regulatory compliance and legal risk?
Contact GOVLAW.
NEWS
Important terms
These updates are a summary only and provided as general information. They do not constitute legal advice or take into account the facts and circumstances of your casino or gaming venue.
The maximum civil penalties under the AML/CTF Act have increased…
Although this change may have passed under the radar for many AUSTRAC-regulated businesses, the civil penalties under the AML/CTF Act have just increased (link here). The maximum, per contravention, for proceedings via the Federal Court has increased from $33 million to $36.4 million.
This is due to the value of the Commonwealth penalty unit being indexed, based on the formula in section 4AA of the Crimes Act 1914 from 1 July 2026.
AUSTRAC orders External Auditor at Club gaming venue's expense
AUSTRAC has ordered the Bankstown District Sports Club Ltd to appoint an external auditor at the Club’s expense, amid concerns its AML/CTF controls may not be strong enough to stop organised crime exploiting poker machines and gambling venues (link here).
According to the AUSTRAC Acting CEO:
In gambling venues, criminals may repeatedly insert cash into poker machines, engage in little or no genuine play, and then cash out – turning illicit cash into funds that appear legitimate. That’s why it’s critical clubs and pubs understand their risks, have strong controls in place and report suspicious activity. Money laundering fuels organised crime and all the harm that comes with it.
It is important to note an external audit at the regulated business’ cost may not be the end of the matter. After Sportsbet’s external audit required by AUSTRAC in 2022, a further court enforceable undertaking was required in 2024. The undertaking required regular reports from the auditor, at Sportsbet’s expense, in addition to their likely substantial legal costs.
AUSTRAC has also been active in enforcement in the Federal Court which imposed civil penalties of $50,000 and $45,000 (plus legal costs) against two companies after they failed to pay infringement notices (link here).
Note: As originally included in our regular compliance update email for July 2026.
If you would like to be added to the email list for GOVLAW AML/CTF compliance updates, please feel free to get in touch.
Andrew Fernbach
Lawyer, GOVLAW
A member of the Commonwealth Association of Legislative Counsel.
© GOVLAW 2026
contact
OUR ADDRESS
GOVLAW
Level 2
696 Bourke Street
Melbourne VIC 3000
(By appointment only)
Liability limited by a scheme approved under Professional Standards Legislation.
For any general inquiries, please fill in the following contact form: