Senet and AHA (Vic) Discuss AML/CTF Compliance for Pubs and Hotels
For pubs and hotels with gaming facilities, staying on top of compliance isn’t just about ticking boxes, it’s about protecting their business and ensuring they meet their legal obligations. With increasing expectations from regulators, many venue operators are looking for practical guidance on anti-money laundering and counter-terrorism financing (AML/CTF) requirements.
To shed light on the challenges and best practices for gaming venues, Senet’s Advisory and Compliance Principal, Alexandra Hoskins, sat down with Mike Barouche, Executive General Manager at the Australian Hotels Association Victoria (AHA (Vic)).
Their conversation delves into the importance of tailored compliance programs and the growing role of AUSTRAC in regulatory oversight.
Mike: It's Mike Barouche here at the members bar, a very familiar place for you all, and today I'm joined by Alex from Senet. Senet is an industry leading expert on gambling law and all the regulatory aspects that affect the pub. Thank you so much for coming today, I really appreciate it.
Alexandra: Pleasure. Thanks, Mike.
Mike: I'm really excited to have you guys on as partners of the AHA, primarily because of the value you can bring to members, and your ability to help members with this very complex regulatory environment. Without a doubt, there are more regulatory reforms in the pub space than any other industry, which makes it the safest place for consumers to come but also makes it an absolute minefield for our members to navigate.
Can you tell me a little bit more about AML/CTF, what you're hearing from regulators and how members can be better prepared?
Alexandra: Thanks Mike. Firstly, I’ll just say that we're really excited to be a partner of AHA, and what we love is just the passion that everyone has for hospitality. But what comes with the privilege of having a gaming license is the obligation to comply with Australian gambling laws and regulation, in particular the Anti-money Laundering and Counter-terrorism Financing Act.
“We often see gaming venues not quite sure how to effectively implement AML within their venues, and some of the challenges that come with potentially not having a dedicated compliance resource. “
It can often seem quite a complex thing to get your head around, and that's what we see venues find quite challenging, because they want to get on and run their hospitality side of the business, but at the same time, you need to make sure that you're complying with gambling laws and regulation and making sure that that's implemented within your venue.
Mike: I couldn't agree more. I think one of the role that the AHA plays is to look after the regulatory side of the business and allowing members to focus on the hospitality side of the business, which is why they got into this industry. And while the AHA is here to support members with template documents and a variety of other tools, you guys are the experts in this space.
How do you take it beyond being an industry template to really help venues with the particular needs that they may have?
Alexandra: So, you would have seen there's been a heightened focus from AUSTRAC, particularly over the last 12 to 18 months - they’ve obviously been going and doing visits to venues. They've been auditing AML programs and risk assessments, and they've actually come to advisors with a range of feedback to set their expectations as to what they want to see and what they don't want to see.
What they don’t want to see is off the shelf tick-the-box programs and risk assessments, because venues need to ensure that they're assessing the reasonable risks that their business faces, and a tick-the-box AML program or risk assessment does not meet that standard.
As well, AUSTRAC’s not seeing venues conduct independent reviews of the AML program and risk assessment and assessing whether it's been effectively implemented within the business. So, there's a little bit of falling short occurring.
Mike: Sounds like quite a role that you're able to play to enhance that process. And while there may be the minimum requirements met, there's certainly a lot more that needs to be done, so we appreciate your help in that regard.
One of the things that I always like to find out from our corporate partners is how you're helping members. And without going into the specifics of which member it was, can you share with us a little bit about the challenges that a pub has had in the past and the impact that you've played in being able to assist them?
Alexandra: I think a lot of venues can find compliance quite daunting. And I guess we share the passion that hoteliers have for the hospitality side. We share that passion from a compliance side of things, and we want to make sure that members are complying with gambling laws and regulations. We also understand that it can be quite complex, so we try and demystify it and make it easier and we do that in a number of ways.
We have very robust programs. We have robust risk assessments that assess the risk for the business.
“Where we really help hoteliers is getting their head around compliance. How do I actually implement this in my business?”
So we have what we call our compliance vault, and that is really an A - Z tool kit designed to help members implement AML Compliance within their venue, and that includes templates and transaction monitoring programs, training registers, all the things that you need to be able to have confidence that you're complying with AML.
Mike: That's fantastic. I really appreciate your time today. I really appreciate the support you bring to members as a partner of the AHA, and I certainly encourage all members, all our gaming members that need to comply, to have a chat with Alex.
Thanks so much.
As AML/CTF compliance continues to be a top priority for regulators, having the right expertise and resources can make all the difference. With AUSTRAC increasing its focus on the gaming industry, it’s more important than ever for pub and hotel operators to ensure they have robust, tailored compliance programs in place.
Senet’s partnership with AHA (Vic) provides gaming venues with the tools, knowledge, and support they need to meet their obligations confidently.
Need guidance on AML/CTF compliance for your business?
Book a complimentary, no-obligation consultation with Alexandra Hoskins, Senet’s Advisory & Compliance Principal. It’s an opportunity to ask any compliance-related questions and explore how we can support you.
