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Sector deep-dive 11 May 2026 8 min read

Pubs and clubs: AML obligations for gaming venues under Tranche 2

Cash thresholds, member screening and the new TTR cadence for venues with electronic gaming machines and TAB outlets.

By Sophie Maddox

Around 4,800 hotels and 1,200 registered clubs in Australia operate gaming machines or wagering outlets. Many of these venues already had reporting obligations under the gambling-specific provisions of the AML/CTF Act; Tranche 2 expands the scope and tightens the supervisory expectations.

What's actually changing

  • Threshold transaction reporting at A$10,000 for cash gaming activity is now strictly enforced — historical under-reporting tolerance is gone.
  • Member identification at the door for venues offering certain higher-value play.
  • Documented source-of-funds enquiries for sustained high-volume play.
  • Mandatory staff training tailored to gaming-floor risk indicators.

Practical implementation

Most venue management systems (Tabcorp, Aristocrat, IGT) now expose AML hooks for the cashier, the gaming floor and the back office. Wire those into a compliance platform that consolidates TTR drafting and SMR escalation rather than running parallel spreadsheets. Complispace and AML SmartGuard both have purpose-built modules for the sector.

Practical next step

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