11/06/24
AML/CTF Programs and Independent Reviews
Members who hold 16 or more gaming machine entitlements and who are therefore required to have an AML/CTF Program in place, are reminded that Part A of the Program must be independently reviewed. The frequency of the review is at the discretion of the licensee based on the venue's risk. If the venue is deemed high risk, AUSTRAC recommend an independent review of Part A of the Program is completed at least once every 2 to 3 years.
The independent review is to be completed by a person that understands the business and the money laundering risk, and who was otherwise not involved in the implementation of the program. This may be someone within the business itself, or an external person such as your accountant or lawyer. If the review is conducted internally, a record of the review must be kept.
The following AHA|SA Corporate Partners have indicated that they may be able to assist with independent reviews:
- Wallmans Lawyers – Ben Allen/Timothy Graham – 8235 3000
- Independant Gaming Analysis – Robert Mullarvey – 8376 6966
We encourage members to support our Corporate Partners where possible. Members should contact Owen, Gary, Sarah or Didier if they have any queries about AUSTRAC or the AML/CTF Programs.