---
title: "AML/CTF program outline for a venue with gaming machines"
url: "https://ailawframework.com/precedents/liquor-gaming-and-wagering-licensing/gaming-venue-amlctf-program-outline"
type: "precedent"
site: "AI Law Framework"
id: "a58-gaming-venue-amlctf-program-outline"
area_id: "A58"
kind: "checklist"
ai_level: "yellow"
version: 1
task_ids: ["A58-Q20261018-4"]
law_stated_as_at: "2026-10-22"
---

# 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…

Canonical page: https://ailawframework.com/precedents/liquor-gaming-and-wagering-licensing/gaming-venue-amlctf-program-outline  
Law stated as at: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

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.

## Key facts

- Kind: Checklist. Steps or checks to work through and tick off.
- Practice area: [Liquor, Gaming & Wagering Licensing](https://ailawframework.com/precedents/liquor-gaming-and-wagering-licensing.md)
- Jurisdictions: Australia, Queensland
- AI level: Yellow. You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the 3 authorities it cites, for Australia and Queensland.

## 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

- [Build the AML/CTF program and reporting obligations for a gaming venue](https://ailawframework.com/practice/liquor-gaming-and-wagering-licensing/build-the-aml-ctf-program-and-reporting-obligations-for-a-gaming-venue.md)

## 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

## Authorities

- [AUSTRAC, Regulatory guide for pubs and clubs with gaming machines (page checked 22 October 2026; guide last updated 9 October 2026)](https://www.austrac.gov.au/industry-and-business/education-and-resources/publications-and-resources/pubs-and-clubs-gaming-machines)
- [Business Queensland, AML/CTF program for gaming machine licensees (reviewed 19 March 2026)](https://www.business.qld.gov.au/industries/hospitality-tourism-sport/liquor-gaming/gaming/electronic-gaming-machines/compliance/anti-money-laundering-counter-terrorism-program)
- [AUSTRAC, Summary of changes for current reporting entities (linked from the Queensland page; read before relying on pre-reform wording)](https://www.austrac.gov.au/amlctf-reform/reforms-guidance/before-you-start/summary-changes-current-reporting-entities-reform)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/liquor-gaming-and-wagering-licensing/gaming-venue-amlctf-program-outline and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*