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Your AUSTRAC Compliance Checklist — 10 Things Every Venue Manager Should Review Monthly

MONTHLY REVIEW

10 Things Every Venue Manager Should Check Every Month

Compliance isn’t a once-a-year exercise. Here’s your monthly checklist to stay on top of AUSTRAC obligations.

Print this checklist.
Pin it in your office. Set a monthly calendar reminder. Run through it on the first Monday of every month. It takes 30 minutes and could save your venue from a compliance failure.

The Monthly Checklist

  1. Review all SMRs filed this month

    Were any suspicious matters identified? Were SMRs filed within the required timeframe (3 business days / 24 hours for TF)? Are there any outstanding matters that haven’t been filed yet?

  2. Check your transaction monitoring

    Review payout reports for the month. Look for patterns: clustering near the $5,000 threshold, unusual frequency, same patrons with multiple payouts. Are your monitoring systems catching what they should?

  3. Verify staff training is current

    Has any new staff started this month? Have they completed AML/CTF induction training? Is anyone overdue for refresher training? AUSTRAC expects ongoing training, not just a one-off session.

  4. Review customer identification records

    Were all payouts of $5,000+ properly identified? Are sight-and-record procedures being followed correctly? Are records complete (name, DOB, address, document type, number, expiry, verification outcome)?

  5. Check your AML/CTF program is current

    Has anything changed in your business this month? New services, new locations, staff changes, technology changes? Your program should reflect your current operations, not last year’s.

  6. Review risk assessments

    Have any customer risk ratings changed? Have you identified any new ML/TF/PF risks? Are there any external factors (media reports, law enforcement alerts, AUSTRAC guidance) that affect your risk assessment?

  7. Audit your record-keeping

    Are transaction records, identification records, and compliance decisions being stored securely? Are records accessible for the required 7-year retention period? Are any records due for secure destruction?

  8. Check sanctions screening

    Are you screening customers against current sanctions lists? Have the lists been updated? Have any new matches been identified that need action?

  9. Review incidents and escalations

    Were any compliance incidents reported this month? How were they handled? Are there any patterns or recurring issues? Do procedures need updating based on what happened?

  10. Confirm compliance officer status

    Is your AML/CTF compliance officer still in role? Are they still fit and proper? Have they reported to the governing body in the last 12 months? Is the next report scheduled?

Quarterly Deep Dives

In addition to the monthly checklist, do a deeper review every quarter:

Q1: Program Review

Full review of your AML/CTF program. Does it reflect current operations? Are policies still appropriate for your risk profile? Update and re-approve as needed.

Q2: Training Audit

Review all staff training records. Identify gaps. Plan refresher training for the next quarter. Update training materials to reflect any regulatory changes.

Q3: Risk Assessment Update

Full risk assessment review covering ML, TF, and PF risks. Update customer risk ratings. Review and update risk controls. Document changes and rationale.

Q4: Annual Compliance Report

Prepare the annual compliance report for your governing body. Summarise the year’s SMR activity, incidents, training, risk changes, and program updates. This is your compliance officer’s statutory reporting obligation.

Common Gaps AUSTRAC Finds

Based on AUSTRAC enforcement actions and guidance, these are the most common failures in pubs and clubs:

1. “We have a program but no one’s read it”
Having an AML/CTF program document is not compliance. Staff must understand it, be trained on it, and follow it. A program that sits in a filing cabinet is worthless.
2. “We rely on staff to spot things”
Manual observation is not systematic monitoring. AUSTRAC has explicitly stated that monitoring systems relying on staff observation alone are inadequate. You need structured, risk-based monitoring.
3. “We’ve never filed an SMR”
If your venue has gaming machines and has never filed an SMR, that’s a red flag for AUSTRAC — not a sign that nothing suspicious has happened. It’s a sign that your detection systems aren’t working.

Document Everything

If it’s not documented, it didn’t happen. AUSTRAC expects to see evidence of your compliance activities — not just assertions that you’re compliant. Keep records of every checklist review, every training session, every decision.
  • Date and sign each monthly checklist review
  • Record who attended each training session and what was covered
  • Document compliance decisions with rationale
  • Keep SMR decision logs — including decisions NOT to file (with reasons)
  • Store everything securely for 7 years

References

  1. AUSTRAC, AML/CTF Program Requirements (Reform) — austrac.gov.au
  2. AUSTRAC, Regulatory Expectations and Priorities 2025–26 — austrac.gov.au
  3. AUSTRAC, Record-keeping overview (Reform) — austrac.gov.au

Automate your compliance checklist

ComplyIQ tracks every obligation automatically — SMR deadlines, training records, risk assessments, and audit trails. Your monthly review takes minutes, not hours.

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