In 2023, the Australian Government announced it would be reforming the AML/CTF regime to:
- Ensure Australia remains compliant with the international standards set by the Financial Action Task Force (FATF), the global financial crime watchdog.
- Improve the regime’s effectiveness.
- Reduce the regulatory burden by simplifying and clarifying the regime, making it easier for businesses, including clubs, to meet their obligations.
ClubsNSW, through Clubs Australia, provided several submissions which focused on a streamlined and clear legislative framework for AML/CTF. Clubs Australia also noted the uniqueness of the club industry.
Directors and other key personnel must continue to be across these changes and upcoming reform in the AML/CTF space to monitor and ensure compliance with legislative requirements.
Current Stage of Reform of AML/CTF Regime
On 29 November 2024, Parliament passed the AML/CTF Amendment Bill, which received royal assent on 10 December 2024. The key changes from the Bill include:
- Changes to the AML/CTF program requirements including:
- Entities completing a risk assessment for ML/TF.
- Emphasis on the role of governing bodies and senior management in overseeing ML/TF/PF risk and AML/CTF compliance (including taking reasonable steps to comply).
- The customer due diligence exemption threshold for the gambling sector from $10,000 to $5000.
- Reforms to the tipping-off offence to allow for information sharing within reporting groups (while ensuring the integrity of investigations).
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