HERE’S WHAT YOU NEED TO KNOW.
AUSTRAC INDEPENDENT EVALUATIONS FOR PUBS & HOTELS
If your pub, hotel or club has entitlements under its licence to operate 16 or more gaming machines, specific Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations apply.
And it’s your entitlements that count – not simply the number of gaming machines you currently operate.
If you’re licensed for 16 or more but currently operate fewer, the 16+ requirements still apply.
aceia can help you understand what applies to your venue(s), when your Independent Evaluation may be due and what your next step should be.
TALK TO ACEIA
Start with a no-obligation discovery meeting to understand your venue, current situation and what you may need to do next.
DOES THIS APPLY TO MY VENUE(S)?
Your AML/CTF obligations depend on the gaming machine entitlements held under your licence, not simply how many machines you currently operate.
QUICK CHECK
Does your licence include entitlements for 16 or more gaming machines?
YES
The 16+ gaming machine AML/CTF requirements apply to your venue.
NO / NOT SURE
Talk to aceia to understand what your AML/CTF obligations are.
THE RULES HAVE CHANGED
From 31 March 2026, changes to Australia’s AML/CTF framework introduced Independent Evaluations of AML/CTF programs, replacing the previous Independent Review requirements.
An Independent Evaluation looks at whether your AML/CTF program and policies are appropriate for your venue(s), whether your money laundering and terrorism financing risks are being identified and managed, and whether your business is following its AML/CTF policies.
WHEN IS YOUR FIRST INDEPENDENT EVALUATION DUE?
31 MARCH 2027
For existing regulated businesses that completed an Independent Review under the previous rules, the first Independent Evaluation is due by the later of:
- 31 March 2027; or
- Four years after the most recent Independent Review.
Not sure when your venue is due? aceia can help you work through what applies to your circumstances and ascertain whether your previous review meets independent review requirements.
IT’S AN ONGOING REQUIREMENT
AT LEAST EVERY 3 YEARS
Your AML/CTF policies must specify how frequently Independent Evaluations will take place, with an evaluation required at least once every three years.
WHAT IS AN AUSTRAC INDEPENDENT EVALUATION?
MORE THAN A TICK-BOX EXERCISE.
Your venue may already have many of the right AML/CTF processes and controls in place. An Independent Evaluation provides an independent check that they’re working as they should and helps identify anything that may need attention.
In many cases, it’s about strengthening or better documenting what you’re already doing.
WHAT CAN AN INDEPENDENT EVALUATION LOOK AT?
✓ Your AML/CTF program and policies
✓ Money laundering and terrorism financing risk assessments
✓ Customer due diligence
✓ Transaction monitoring
✓ AML/CTF staff training
✓ Employee due diligence
✓ AUSTRAC reporting
✓ Governance and management oversight
✓ Record keeping and outsourced activities
WHY INDEPENDENCE MATTERS
The person conducting your Independent Evaluation needs to be appropriately independent from the AML/CTF program and controls being evaluated.
This provides an objective and unbiased view of how your program is working and where attention may be needed.
WHAT TO EXPECT FROM ACEIA
01
UNDERSTAND
We get to know your venue(s), gaming operations and what AML/CTF arrangements you currently have in place.
02
REVIEW
We review your available AML/CTF program and associated policies, risk assessments, processes, training, records and other relevant documentation.
03
TEST
Where controls and processes are in place, we assess how they’re working in practice.
04
REPORT
You receive clear findings and practical recommendations on what needs attention. The exact scope is tailored to your venue(s), what you currently have in place and AUSTRAC expectations for the pubs and clubs sector.
WHAT ARE THE BENEFITS?
✓ CONFIRM WHAT’S WORKING
Get an independent view from AML qualified professionals about the processes and controls you already have in place.
✓ IDENTIFY GAPS
Find areas in your program, documentation or processes that may need attention.
✓ FOCUS YOUR EFFORT
Know where to prioritise your time and resources.
✓ BE BETTER PREPARED
Strengthen your AML/CTF arrangements now and make future Independent Evaluations easier to manage.
WHY ACEIA?
aceia brings together specialist AML/CTF knowledge, extensive audit and risk experience, and local South Australian support.
PETER FRANCIS | Founder & Managing Director, aceia
Peter has more than 25 years’ experience in internal audit, risk and compliance. He founded Adelaide-based aceia in 2007 and works with organisations to provide practical assurance, relevant reporting and recommendations.
TARIQ ISLAM | AML/CTF, Risk & Internal Audit Specialist
Tariq has 20 years’ experience in risk management, compliance and internal audit, including more than a decade working in AML/CTF remediation and Independent Reviews. His experience includes senior internal audit roles with CBA and Westpac and AML/CTF remediation work and AML/CTF Independent Reviews with PwC.
GIRIDHAR “GIRI” KANNAN | AML/CTF Specialist & Lead Auditor
Giri has more than 20 years’ experience in anti-financial crime, compliance programs and regulatory assessment. His background includes experience as a first-line regulator and financial crime internal auditor with Westpac Group during and post AUSTRAC enforcement. He also holds Advanced ACAMS-AUDIT certification.
EXPERIENCE WITH SOUTH AUSTRALIAN VENUES
“Peter Francis and his team assisted us in making our AUSTRAC requirements seamless and relatively easy. They helped us implement systems so that when we do this again, the process will be pain-free. We highly recommend them.”
Josie & Tony O’Donnell
The Aldgate Pump Hotel
FREQUENTLY ASKED QUESTIONS
UNDERSTANDING YOUR REQUIREMENTS
My venue is licensed for 16 or more gaming machines but operates fewer. Do the requirements still apply?
Yes. The AML/CTF requirements are based on the number of gaming machine entitlements under your licence, not simply the number of machines currently operating.
So, if your venue has entitlements for 16 or more gaming machines but currently operates fewer, the 16+ requirements still apply.
How do I know when my first Independent Evaluation is due?
For existing regulated businesses that completed an Independent Review under the previous Rules, the first Independent Evaluation is due by the later of:
- 31 March 2027; or
- Four years after your most recent Independent Review.
If you’re unsure when your venue is due, aceia can help you work through your circumstances and ascertain whether your previous review meets independent review requirements.
How often will I need an Independent Evaluation?
Your AML/CTF policies need to specify how often Independent Evaluations are conducted, with an evaluation required at least once every three years.
What’s the difference between an Independent Review and an Independent Evaluation?
From 31 March 2026, Independent Evaluations of AML/CTF programs replaced the previous Independent Review requirements.
An Independent Evaluation looks at whether your AML/CTF program and policies are appropriate for your venue(s), whether your money laundering and terrorism financing risks are being identified and managed, and whether your business is following its AML/CTF policies.
ABOUT THE INDEPENDENT EVALUATION
What does an Independent Evaluation look at?
The exact scope depends on your venue(s) and circumstances. It can include your:
- AML/CTF program and policies
- Money laundering and terrorism financing risk assessments
- Customer due diligence
- Transaction monitoring
- AML/CTF staff training
- Employee due diligence
- AUSTRAC reporting
- Governance and management oversight
- Record keeping and outsourced activities.
What if we already have AML/CTF processes in place?
That’s a good starting point. An Independent Evaluation provides an independent check of how your existing processes and controls are working and helps identify anything that may need attention.
In many cases, it’s about strengthening or better documenting what you’re already doing rather than starting again.
What if we don’t have everything in place yet?
You don’t need to have everything sorted before talking to aceia.
We start by understanding your venue(s), gaming operations and what AML/CTF arrangements you currently have in place. The scope of the evaluation is then tailored to your venue(s), your current arrangements and AUSTRAC expectations.
Why does the person conducting the evaluation need to be independent?
The person conducting your Independent Evaluation needs to be appropriately independent from the AML/CTF program and controls being evaluated.
This provides an objective view of how your program is working and where attention may be needed.
What will we receive at the end of the evaluation?
You’ll receive a report including clear findings and practical recommendations on what needs attention.
The aim is to help you understand what’s working, identify gaps and know where to focus your effort.
WORKING WITH ACEIA
I’m not sure whether we need an Independent Evaluation. Can I talk to someone first?
Absolutely. You don’t need to have all the answers before contacting aceia. An initial conversation can help you understand what applies to your venue(s) and what your next step should be.
As an AHA|SA member, you can also contact the Association for advice and insights on Independent Evaluations.
Your conversation with aceia is complimentary and comes with no obligation.
Contact us on 1300 791 794 or +61 8 8133 4900, or email info@aceia.com.au.
How much does an Independent Evaluation cost?
The cost will depend on the scope of the evaluation and your venue’s circumstances, including the complexity of your operations and the AML/CTF arrangements you currently have in place.
Before any work begins, we’ll discuss your requirements and the proposed scope so you understand what’s involved and the associated cost.
How long does an Independent Evaluation take?
The timeframe will depend on your venue(s), the scope of the evaluation, the AML/CTF arrangements you currently have in place and the availability of the information required. Evaluations typically take between 4 to 6 weeks.
We’ll agree the scope and expected timeframe with you before commencing the evaluation.
Will you need to visit our venue(s)?
Yes, site visits are required for each venue. The nature and duration of the site visit(s) depend on the scope and circumstances of your Independent Evaluation.
We’ll let you know what is required as part of the agreed scope before the evaluation begins.
What information will we need to provide?
The information required will depend on your venue(s) and what you currently have in place.
This typically includes your AML/CTF program and policies, risk assessments, training records, relevant reporting and records, and information about the processes and controls used within your gaming operations.
If you’re not sure what you have or where to start, we’ll explain what we need and work through it with you.
We operate more than one venue. Can the Independent Evaluation cover multiple venues?
If your business operates multiple venues, we’ll first look at how your AML/CTF arrangements are structured across the group and the circumstances of each venue.
From there, we can determine the appropriate scope for the Independent Evaluation and discuss the most practical approach with you.
STILL HAVE QUESTIONS?
Every venue is different. Talk to aceia about your circumstances, existing AML/CTF arrangements and what you may need to do next.
NOT SURE WHERE YOUR VENUE STANDS?
You don’t need to have all the answers before you contact us.
A short conversation can help you understand what applies to your venue(s) and what your next step should be.
Your conversation with aceia is complimentary and comes with no obligation.
Prefer to contact us directly?