Checklist · Liquor, Gaming & Wagering Licensing
AML/CTF program outline for a venue with gaming machines
An outline for a pub or club licensed to operate electronic gaming machines: enrolment with AUSTRAC, what the program must cover, the annual compliance report and suspicious matter reporting, with the post-March 2026 reforms left for the current AUSTRAC page.
- Kind
- Checklist. Steps or checks to work through and tick off.
- Where it applies
- Australia, Queensland
- AI use
- Yellow You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at
- 22 October 2026
- Status
- Maintained. Checked on 22 October 2026 against the 3 authorities it cites, for Australia and Queensland.
- Version
- 1
- Source
- Written for this library
When to use it
Use when a gaming-machine venue needs an AML/CTF program or a gap check against the obligations AUSTRAC and the Queensland regulator describe. It is not the program. Read AUSTRAC's current guide and reform pages before the program is adopted.
Used for these tasks
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
AI may turn the venue's procedures into a gap list against the headings below. The lawyer decides the risk assessment and what is reported to AUSTRAC. The program is adopted by the venue, not by the tool.
AI may
- List which headings have no procedure, no owner or no review date
- Index existing policies against enrolment, the program, the annual compliance report and suspicious matter reporting
- Remind the drafter that the Queensland page describes reforms from 31 March 2026 and that the current AUSTRAC reform page must be read
AI must not
- Must not decide that a transaction is or is not suspicious
- Must not lodge an AUSTRAC report or enrol the venue
- Must not copy customer identity documents into a tool that is not approved for that information
The lawyer checks
- The venue is in fact licensed to operate electronic gaming machines, so the AUSTRAC pubs-and-clubs guide is the right one
- Enrolment is current, and the program states how the venue will comply and how it will identify, reduce and manage money-laundering and terrorism-financing risk
- The annual compliance report and suspicious matter reporting are owned by a named person
- The program has been read against AUSTRAC's reform guidance after 31 March 2026, not only against a pre-reform template
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
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The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
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