AML/CTF and State Gaming Compliance for Australian Pubs and Clubs

One platform for the dual compliance reality every Australian gaming venue lives. AUSTRAC AML/CTF on one side, state gaming regulators on the other, hospitality compliance underneath – delivered in a single integrated system built specifically for community venues.

 

The ComplyIQ Capability Set

One Platform. Seven Connected Modules. Operational AML/CTF.

Patron risk profile feeds the payout window. Transaction monitoring reads from EGM data. SMR pipeline contains the tipping-off boundary. Audit trail records every decision. Not seven separate tools that need integrating – one platform with seven modules across two operating layers.

Multi-tenant architecture (Group → Venue)

Role-based access control (RBAC)

Centralised policy inheritance

Australian data residency (ap-southeast-2)

Single sign-on with MFA

Real-time compliance dashboard

SMR - SMR -  - ComplyIQ - ComplyIQ

Core Compliance

Customer due diligence, monitoring, screening, reporting.

The AUSTRAC obligation set, operationalised at the payout window where it matters.

CDD & KYC

Ongoing Customer Due Diligence

Identification at the regulatory threshold or risk-based trigger, risk-tier assignment, ongoing CDD with re-assessment cycles. Sight-and-record without document copying – aligned to the post-March 2026 reform.

Guided identity capture workflow

PEP & sanctions screening built in + integration for OpenSanctions

Dual-bucket risk scoring (0–100)

Occupation-based risk weighting (ABS OSCA)

Geographic risk via ABS SEIFA
data

Duplicate detection & merge
workflow

Transaction Monitoring

Transaction monitoring & behavioural alerts

Real-time structuring detection, velocity monitoring, wealth-gap analysis, and behavioural pattern tracking. Alerts fire at the payout window, not in next month’s report.

Automated typology etection
engine

12+ built-in typologies (Wash,
Smurf, etc.)

Staff observation wizard (Quick-Flag)

Tiered alerting (P1–P3)

Tipping-off safe UI masking

Integration with gaming systems (MAX)

SMR Reporting

SMR filing, evidence & AUSTRAC reporting

Suspicious matter report pipeline from staff observation to AUSTRAC submission. Section 123 tipping-off controls enforced by role-based access architecture.

Mode 1: Staff observations
(guided wizard)

Mode 2: Formal SMR lodgement (compliance)

AUSTRAC reason code

Automated evidence pack
generation

7-year immutable record
retention

Case management &
investigation workbench

Sanctions & PEP

Screening & Match Resolution

Politically exposed person and sanctions screening with per-patron 90-day validity tracking. Match resolution routed to the compliance officer. ECDD triggered automatically for confirmed PEPs.

PEP screening with per-patron 90-day validity tracking

OpenSanctions integration for global sanctions coverage

Domestic, foreign, and family/associate PEPs flagged separately

Match resolution wizard for compliance officer review

Auto-triggered ECDD for confirmed PEPs

Automatic re-screen on validity expiry

Operation & Governance

Cash controls, risk program, audit trail.

The day-to-day operations that turn a written program into evidenced compliance.

Gaming & Cash Controls

Risk at the point of play

Patron risk tier, screening status, and identification all visible at the moment of payment. Threshold and cash-limit enforcement built in.

Patron risk-tier visible at the payout window (LOW / MEDIUM / HIGH)

Cash payout threshold enforcement at the cage

Self-exclusion register check at entry and at payout

ATM placement and per-transaction limit config per state regulator

Compliance officer authorisation invisible to the patron

Tipping-off-safe staff view -no SMR existence visible

Risk Assessments & Program

Living document, operational

Living risk assessment that drives the program. Risk-tier framework, program-level controls, governance approval workflow, independent evaluation tracking. The program operates rather than just being documented.

AUSTRAC four-dimension framework (customer, channel, product, jurisdiction)

 

Quantified risk profile per venue with named risk drivers

Group-level + venue-level adaptation for multi-site operators

Trigger-based refresh (legislation, ownership, incident)

Board approval workflow with versioning and audit log

Independent evaluation tracking with remediation status

Audit Trail & Records

Seven-year evidence

Tamper-evident records, time-stamped decisions, exportable in formats the regulator can read directly. Every payout, every screening, every escalation captured as a by-product of running the program.

Per-patron file: ID, risk, screening, transactions, ECDD, SMRs

Tamper-evident record architecture – every edit logged

Time-stamped to original event, not entry timestamp

AUSTRAC-format export – CSV, PDF, regulator templates

Search across patron, date, event type, machine, staff member

Read-only historical versions with full change audit trail

Built for the Community Venue

Pubs, Clubs, Hotels, RSLs.

Purpose-built for community gaming venues – not casinos, not generic compliance management, not ID-scanning vendors with an AML wrapper.

 

For Pubs

Hotel licence operators with gaming machines – from single-pub operators to hotel groups. Liquor and gaming compliance integrated, AUSTRAC obligations operationalised, RSA and AML/CTF training tracked together.

For Clubs

Registered clubs, leagues clubs, RSL clubs, and community clubs. Member management alongside AUSTRAC and state gaming compliance. Group oversight for multi-venue club groups; venue-level execution at each location.

State Gaming Compliance Built In

L&GNSW, VGCCC, OLGR, CBS - covered.

Federal AUSTRAC and state gaming regulator obligations live together in the same workflow. Digital Incident Register (NSW), YourPlay tracking (VIC), OLGR records (QLD), and CBS gaming compliance (SA) all in the venue’s existing platform.

 

NSW Gaming Compliance Guide

VIC Gaming Compliance Guide

QLD Gaming Compliance Guide

The Authority Network

ComplyIQ Doesn't Stand Alone.

The platform sits inside an authority network that spans program design, independent review, and operational delivery. Three independent businesses, one coordinated answer for venues that take compliance seriously.

 
 

Program Design

The AML Company

17 years of AUSTRAC consulting for Australian pubs and clubs. Program design, ECDD operationalisation, risk assessment writing, and compliance officer support.

Independent Review

RCA Group

Independent AML/CTF reviews and pre-audit mock reviews. The kind of review AUSTRAC eventually does, conducted privately first so you can fix what they find before the regulator does.

See ComplyIQ in Action

Book a demo to see live patron risk profiles, group oversight, payout-window controls, and the integrated audit trail operating together – the same platform your compliance officer would use on day one.