1. Overview
The Reef Hotel Casino operates as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and the associated AML/CTF Rules. This policy sets out the obligations and procedures relating to anti-money laundering, counter-terrorism financing, and know-your-customer requirements as they apply to operations in Australia.
All gambling services provided by The Reef Hotel Casino are classified as designated services under the AML/CTF Act. The Reef Hotel Casino is enrolled with AUSTRAC (the Australian Transaction Reports and Analysis Centre) and is required to maintain a documented, risk-based AML/CTF program that is formally adopted by senior management.
This policy applies to all patrons, account holders, and any person seeking to access designated services at The Reef Hotel Casino.
2. AML/CTF Program
The Reef Hotel Casino maintains a documented AML/CTF program that covers the following core elements:
- An assessment of money laundering and terrorism financing (ML/TF) risk specific to the operations and customer profile
- Written customer identification and verification procedures (KYC)
- Ongoing customer due diligence (CDD) and transaction monitoring
- Procedures for identifying and reporting suspicious activity
- Record-keeping arrangements
- Staff training requirements
The program is reviewed regularly and updated to reflect changes in legislation, AUSTRAC guidance, and the assessed risk profile. An appointed AML/CTF Compliance Officer holds responsibility for day-to-day implementation and oversight of the program.
3. Customer Identification (KYC)
3.1 When identification is required
Customer identity must be verified before designated services are provided in the following circumstances:
- Prior to creating an account or commencing a designated service for online gambling customers (mandatory from 29 September 2024 under AUSTRAC’s strengthened customer identification requirements)
- Prior to paying out winnings or completing transactions at or above the prescribed monetary threshold for land-based gaming services
- When enhanced due diligence is triggered by a customer’s risk profile or activity
As of 31 March 2026, the mandatory customer due diligence threshold for gambling service providers is AUD 5,000. This applies to:
- Single payouts of AUD 5,000 or more
- Multiple linked payouts totalling AUD 5,000
- Equivalent cashless or card-based transactions totalling AUD 5,000
No payout at or above this threshold is made without completed identity verification.
3.2 Information collected
To verify a customer’s identity, the following minimum information is collected and confirmed:
- Full legal name
- Date of birth
- Residential address
Verification is conducted against reliable and independent documents or electronic sources. Records are kept of the identity documents sighted and the process by which verification was completed.
3.3 Customer due diligence tiers
Customer due diligence obligations are structured across three tiers, depending on assessed risk:
| Tier | Description |
|---|---|
| Simplified CDD | Applied in limited, low-risk circumstances as permitted under AUSTRAC guidance; ongoing monitoring still applies. |
| Standard CDD | Applied to the majority of customers at onboarding and throughout the relationship. |
| Enhanced CDD (ECDD) | Applied to higher-risk customers, including politically exposed persons (PEPs) and those flagged through sanctions screening. |
All customers are risk-rated at the point of initial identification. PEP screening and sanctions checks are conducted as part of initial CDD and are maintained on an ongoing basis.
4. Ongoing Monitoring
Customer due diligence continues after onboarding. Ongoing monitoring of customer transactions and activity is conducted to identify patterns that may indicate money laundering, terrorism financing, or other serious criminal conduct.
Monitoring includes scrutiny of:
- Transaction volumes and frequencies that are inconsistent with a customer’s known profile
- Structuring activity (breaking up transactions to avoid reporting thresholds)
- Use of value-holding instruments, including gaming chips, stored-value cards, and loyalty program balances
- Requests for unusual payment arrangements or third-party payouts
Where activity is identified as suspicious, it is escalated internally and assessed for reporting to AUSTRAC.
5. Reporting Obligations
As a reporting entity, The Reef Hotel Casino submits the following reports to AUSTRAC:
- Threshold Transaction Reports (TTRs): Filed for physical cash transactions of AUD 10,000 or more.
- Suspicious Matter Reports (SMRs): Filed when there are reasonable grounds to suspect that a transaction or customer may be connected to money laundering, terrorism financing, or other serious crime. SMRs may result in account suspension or termination of the customer relationship where warranted.
- Annual Compliance Reports: Submitted to AUSTRAC each year as required under the AML/CTF Act.
Customers are not notified when an SMR has been filed, as doing so may constitute tipping off under Australian law.
6. Beneficial Ownership
Where a customer is acting on behalf of a company, trust, or other complex entity, beneficial owners of that entity must be identified and verified. Customers must provide accurate and complete information about the underlying ownership structure before designated services are provided.
7. Record-Keeping
All KYC records, verification evidence, transaction records, and related documentation are retained for a minimum of seven years. Records include copies of identity documents and documentation of the verification process itself, consistent with AUSTRAC requirements.
8. Virtual Assets
From 1 July 2026, where operations involve virtual assets or digital currencies, the Travel Rule is applied. This requires that accurate originator and beneficiary information accompanies each digital asset transfer, in line with Australia’s updated AML/CTF framework.
9. Customer Obligations
Customers are required to:
- Provide accurate, complete, and current identity information when requested
- Cooperate with identity verification procedures before accessing designated services or receiving payouts
- Notify The Reef Hotel Casino of any material changes to their identity information or beneficial ownership structure
- Not engage in structuring, layering, or any other conduct designed to circumvent AML/CTF obligations
Failure to provide required information results in the refusal or suspension of services. Providing false or misleading information may be referred to relevant authorities.
10. Amendments to this Policy
This policy is reviewed and updated in line with changes to the AML/CTF Act, AML/CTF Rules, and AUSTRAC guidance. The current version of this policy is available upon request. Continued use of the services of The Reef Hotel Casino constitutes acceptance of the applicable version of this policy.