Tranche 1 · Gambling
AML compliance for casinos, bookmakers and gambling operators
Gaming, betting and chips/currency exchange are designated services. High transaction volume and cash intensity require robust customer due diligence, ongoing monitoring and suspicious matter reporting that fit operational realities.
Need specialist support? Speak with our in-house team.
Am I captured?
Casinos, bookmakers and other operators providing designated gambling services are reporting entities.
Designated services include:
- Gaming and betting services that are designated
- Exchanging money for chips, tokens or other gaming instruments, and the reverse
- Paying out winnings where that activity is a designated service
Venue count is not the test — the service is.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. Cash intensity and high transaction volume are the risk. Know the customer at the threshold that applies to your venue or channel, watch for structuring, and report suspicions without tipping the patron.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your gambling operation could be used for money laundering or terrorism financing — customers, services, venues or channels and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how your gambling operation will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
This is a plain-English guide, not a determination of your status. If unsure, use the Am I in scope? guide or speak with us.
How Trancher helps
Customer due diligence, ongoing monitoring and reporting built around high transaction volumes, threshold-based checks and structuring risk across venues and channels.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your operation — use Trancher within your existing AML/CTF operations, add expert support where needed, or have agreed activities managed for you.
Path 1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
Path 2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with implementation, risk assessment, program updates, onboarding, training or operational reviews.
Path 3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your operation’s behalf.
Need specialist support? Speak with our in-house team.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
Guides and articles for gambling operators
Questions from gambling operators
Am I captured?
Casinos, bookmakers and other operators providing designated gambling services are reporting entities. Venue count is not the test — the service is.
What are the deadlines?
[Answer needed — deadlines and enrolment timing for Tranche 1 entities]
What goes in the program?
[Answer needed — program content for a gambling operator]
What does CDD look like in practice?
[Answer needed — CDD in practice for gambling operators]
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.