In 2022, AUSTRAC embarked on a nationwide education campaign to help pubs and clubs that operate electronic gaming machines (EGMs) understand their anti-money laundering and counter-terrorism financing (AML/CTF) obligations, protect their business and keep the community safe.

We reached over a thousand venues, answered questions specific to the operation of each business and shared practical tips on how to identify and report suspicious customer behaviour to AUSTRAC.

Since then, we have seen a significant increase in the submission of suspicious matter reports (SMRs) from businesses, which has been critical in helping us to detect, deter and disrupt criminal activity. To support these ongoing efforts, we have updated and developed several new resources to help improve your reporting.

These resources include:

• a list of suspicious activity indicators to help you identify potential money laundering, terrorism financing and other serious and organised criminal activity at your venue

• an updated brochure and poster outlining AML/CTF tips to help protect your business, plus myths and facts around money laundering and terrorism financing

• a video highlighting examples of what money laundering can look like in pubs and clubs, no matter how small or big the venue.

All pubs and clubs are required to provide AML/CTF risk awareness training to their staff, to help them minimise the risk of your business being used to support criminal activity. While these resources do not replace your AML/CTF risk awareness training program, they can be used to help fulfil this requirement.

These resources can also be used in combination with our existing learning materials including our ALM/CTF e-learning modules and collection of guidance resources dedicated to helping you understanding your obligations.

Suspicious activity indicators

EGMs are cash intensive and criminals attempt to take advantage of the anonymity and ease of access to the pubs and clubs industry to launder their proceeds of crime.

Be on the lookout for suspicious customer activity, including customers who:

• attempt to buy winning tickets from other patrons

• ask for cheques or EFTs to be written in someone else’s name

• avoid identification procedures

• use counterfeit notes

• use large sums of cash, but records indicate minimal or no play

• have unexplained sources of wealth or funds and/or it’s inconsistent with their profile.

What you need to do

If you suspect that a customer or transaction is linked to a crime, you are required to submit a suspicious matter report to AUSTRAC.

No single suspicious activity indicator will be a definitive way to identify if your business is being exploited by criminals. Make sure to use a combination of indicators highlighted in the resources plus conduct further monitoring. This list is not exhaustive and you should consider other indicators specific to your business’s individual risk profile and circumstances.

If you identify suspicious activity you should conduct enhanced customer due diligence in line with your AML/CTF program.

More information

For more information on how to stop criminals from laundering the proceeds of crime through electronic gaming machines, see our pubs and clubs guidance resources.