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.
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.
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.
1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
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.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
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
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View article →Questions from gambling operators
Am I captured?
Casinos, bookmakers and gambling operators have been reporting entities under Tranche 1 when they provide designated gambling services. Obligations depend on the specific services provided.
What are the deadlines?
Tranche 1 obligations have applied for years. Enrolment must be kept current, including nomination of an AML/CTF Compliance Officer. Focus is on ongoing compliance rather than a new Tranche 2 deadline.
What goes in the program?
Your AML/CTF program must include a risk assessment of gambling activity and the controls to manage ML/TF risks — customer identification where required, monitoring of higher-risk activity, PEPs/sanctions/adverse media screening, suspicious matter reporting, staff training and record-keeping.
What does CDD look like in practice?
Apply customer due diligence as required by your designated services and risk assessment. Screen for PEPs, sanctions and adverse media, and monitor activity. Records must be retained to demonstrate compliance.
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.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.