Key AML/CTF Insights from Recent Conference

Below we share several important takeaways relevant to members, particularly considering the anticipated reform, as well as give insight into ClubsNSW advocacy and support for members.

AUSTRAC’s Keynote Address

AUSTRAC’s keynote address highlighted emerging financial crime risks, with particular attention given to cryptocurrency and crypto ATMs, noting their presence in some pubs and clubs. Attendees were cautioned of the high financial crime risk these pose.

AUSTRAC promoted its shift towards becoming an outcomes-focused regulator. This means that while enforcement remains a priority, there is a growing emphasis on education and capability uplift, especially for entities deemed “lower risk”. 

Governance and Oversight

A key theme throughout the conference was the importance of mature governance practices. With upcoming AML/CTF reforms set to reshape oversight requirements, ClubsNSW is proactively planning its support for members through these changes. The reforms present a valuable opportunity to strengthen governance frameworks and enhance oversight across our industry sector.

Importantly, effective oversight goes beyond reviewing reports and graphs. It requires active engagement, including challenging assumptions, asking critical questions, and seeking assurance that the information presented is supported by well-functioning systems and processes.

Independent Reviews and Continuous Improvement

The current requirement for “Independent Reviews” will soon be rebranded as “Independent Evaluations”. Despite the name change, the core expectations remain. Evaluations must assess your ML/TF risk assessment, including the methodology used for its design and review; the structure and effectiveness of your AML/CTF policies; and whether your controls adequately mitigate identified risks. Additionally, evaluators must test overall compliance with your AML/CTF obligations to ensure your program is both effective and fit for purpose.Attendees were cautioned against viewing a “clean” independent review report as a definitive sign of compliance. In some cases, it may reflect a lack of depth in the review process, or deficient capability of an adviser.

Supporting Members Through the Reform

As the regulatory environment continues to evolve, ClubsNSW is exploring ways to assist members, including through updated guidance materials. Our goal is to ensure clubs are well-prepared and confident in meeting their AML/CTF obligations.

We will be hosting an AML/CTF compliance series covering the range of AML/CTF obligations. Members can subscribe to be notified as episodes are released.

ClubsNSW’s Advocacy for Members

Over the past 12 months, ClubsNSW has actively engaged with AUSTRAC throughout the drafting process of proposed amendments to the AML/CTF legislation. We have consistently advocated for balanced and practical regulatory reform that reflects the operational realities of our members.

More recently, we have been working closely with the regulator to support the development of detailed compliance guidance, which will be hosted by AUSTRAC. This guidance aims to assist clubs in understanding and implementing their obligations under the evolving AML/CTF framework.

ClubsNSW will continue to keep members informed as further clarity emerges regarding the future direction of the AML/CTF regulatory framework.