Does Independent review of AML/CTF program apply to gambling and wagering businesses?

Independent review of AML/CTF program. Under the reformed AML/CTF Act, the former independent review of a Part A program has been replaced by an independent evaluation of the whole AML/CTF program (ML/TF risk assessment and AML/CTF policies). It must happen at least once every 3 years, at a frequency set in your AML/CTF policies.

Trigger: Having an AML/CTF program in place.

Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 27 of those industries the answer for "Independent review of AML/CTF program" is no. Gambling & wagering is one of the 8 where the answer is different: yes.

The deciding fact for gambling and wagering businesses: Gambling services are AML/CTF designated services (s 6 table 3)

About the industry: Operators of gambling, betting, and lottery services.

Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service).

Each cell is the engine's outcome for a business in gambling & wagering with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.

When due

At least once every 3 years, at the frequency set in your AML/CTF policies. Newly regulated entities: first evaluation due 30 June 2029 – 31 December 2030 depending on AUSTRAC account number.

Evidence to keep

Independent evaluation scope, evaluator independence record, evaluation report, governing body response, remediation tracker.

Maximum penalty

Civil penalty of up to $36.4M (body corporate) or $7.28M (individual), maximum per contravention, under the general AML/CTF Act civil penalty regime

Regulator

AUSTRAC

Jurisdiction

Commonwealth (national)

• Customer due diligence (KYC) on every customer: Yes
• Designate an AML/CTF Compliance Officer: Yes
• Detect + enhance due diligence on Domestic + Foreign PEPs: Yes
• Enrol with AUSTRAC as a reporting entity: Yes
• Maintain a written AML/CTF program: Yes
• Suspicious matter, threshold, and IFTI reporting to AUSTRAC: Yes
• All 12 answers for gambling & wagering

• Real estate agents: Yes
• Accountants & bookkeepers: Yes
• Lawyers & solicitors: Yes
• Conveyancers: Yes
• Trust & company service providers: Yes
• Precious metals & stones dealers: Yes
• Banks & ADIs: Yes