Industry guide
Pubs & Clubs
Hotels, pubs and registered clubs operating gaming machines or providing other gambling services have specific obligations under AUSTRAC Tranche 2 from 1 July 2026.
Key obligations
Identify your gambling-related designated services
EGMs, TAB outlets, keno and bingo all carry distinct obligations.
Enrol with AUSTRAC
Each separately licensed venue or operating entity must enrol.
Adopt a venue AML/CTF program
Cover gaming room procedures, cash handling, TITO tickets, and incident escalation.
TTRs and SMRs
Threshold reports for $10,000+ cash transactions; suspicious matter reports whenever staff form a suspicion.
Train gaming and cash staff
Frontline staff need annual AML training on red flags such as structuring and chip-dumping.
Common pitfalls
Relying on club membership for KYC
Membership data is rarely sufficient verification under the AML/CTF Rules.
No process for cuckoo-smurfing red flags
Multiple small deposits across machines or accounts can indicate structuring.
Weekend cash-out blind spots
After-hours cash-outs without a documented process are a common audit finding.
Frequently asked questions
Are venues without gaming caught?
Pubs and clubs that do not provide gambling services are generally not reporting entities under the gambling category, though other designated services may still apply.
Who is responsible — the club or the operator?
The reporting entity is the holder of the gaming licence. Outsourced gaming managers do not transfer the obligation.
Not sure where you stand?
Take our free 3-minute Tranche 2 readiness quiz to get a personalised risk score and next-step roadmap for your business.