Objective
To provide employees with guidelines to ensure the clubs legal obligations to have an Anti-Money Laundering and Counter Terrorism Financing Act.
Responsibilities
Employee
- All employees are required to report all suspicions and concerns to their Supervisor/Manager.
Manager/Supervisor
- Fill out a Threshold Transaction Report (TTR) and File it where appropriate.
- Provide an employee note on DCR and fill Incident Report Book where appropriate.
- Follow up with General Manager/Compliance Officer.
Compliance Officer
- The Compliance Officer will be complying with the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth).
- The Compliance Officer will conduct such further enquiries as he deems appropriate after consultation with the General Manager which may include a report to the Australian Transaction Reports and Analysis Centre (AUSTRAC) through their official notification system.
- Compliance Officer is also responsible for providing reports to the General Manager and the Board of Directors.
- Records generated as part of this program are to be scanned and saved as a soft copy. The hard copy will need to be kept for 7 years and then securely destroyed.
Procedures
What does the club need to report?
- Clubs must report cash transactions for amount of $10,000 or more for gaming machines and TAB
- The club is required to make reports about certain suspicious activities.
What should I be on the lookout for?
- False name and address provided; Example: someone may use a name different to that on their ID.
- Purchase of winning tickets; Patron A wins a prize at the club on a Members Draw, TAB, Keno, Gaming Machine or Link. Patron A then give the prize-winning ticket to Patron B, so it looks like Patron B won the prize. Patrons who redeem prize-winning tickets a couple of days after winning a large prize should be considered suspicious.
- Abnormal play and credit redemption; A patron inserts large amounts of cash into a gaming machine and then collects a payout after a short time. In the TAB area a customer could place a large bet and then cancel it.
- Stolen or Counterfeit Notes; Patron may try to exchange or spend stolen or counterfeit money.
- Patron may insert stolen or counterfeit money into the note acceptor of the gaming machine, play for a while, and then collect.
- Clearance staff should be on the lookout for suspicious notes.
- Collusion between staff and money launderers; A corrupt staff member may alert the money launderer to significant payout situations and facilitate the introduction of the prize-winner and the money launderer. Staff may also be involved in other ways with money launderers.
- Other suspicious activities: It is best to report activities that make you feel uncomfortable, no matter what they are. Suspicious activities do not just involve money or gambling. For example, a staff member reported a patron who wanted to know about the exact opening and closing times of the club and who was at work then.
What do I do if I see something suspicious?
- DO NOT ALERT THE INDIVIDUAL TO YOUR SUSPICION.
- Report suspicious activity to Manager/Supervisor as soon as possible after you become aware of it.
- Try to identify the person or persons involved in the suspicious activity.
- Details are important – what was said, what was done, when and where.
- It can be helpful to write down the details – Manager/Supervisor is to fill out the incident report book
- Manager/Supervisor is to report to the Compliance officer.
- Compliance Officer my make further investigation.
- Compliance Officer is to consult with General Manager on the issue and may make a report about the suspicious activity to AUSTRAC.
- AUSTRAC will use the information provided to identify money laundering and terrorism financing activities and make Australia a safer place.
Reporting Threshold Transactions
- The Club sends reports about gaming machine threshold transactions to AUSTRAC. Payments of $10,000 or more should be reported and the following information MUST be collected using reliable identification.
- Full name
- Residential Address
- Date of birth.
- Forms to be filled out including, AML/CTF Program Payouts, ECDD and KYC on lighthouse.
- Valid identification must be scanned.
- The TAB makes reports about TAB threshold transactions.
SUMMARY:
- Be on the lookout for suspicious activity and unusual or suspicious activities to the Manager/Supervisor.
- Manager/Supervisor is to notify Compliance Officer as soon as possible.
- Get as much information as possible.
- Do not alert the individual/s.
- Manager/Supervisor is to fill out a Transaction Threshold Report and file it to the Compliance Officer.
- Compliance Officer is required by law to make reports about suspicious activity and threshold transactions to AUSTRAC
- Get copy of driver’s license for TAB cash payouts of $10,000 or more
Breach of Policy
Strathfield Sports Club has an obligation to consistently apply and enforce this policy. Employee must understand and comply with this policy.
Any employee who breaches this policy shall be subject to counselling, training, and/or disciplinary action, which may include termination of employment.
| Version | Authorised by | Date Reviewed | Next Review Date |
| 2 | Phillip Truong | 03/07/2023 | 03/08/2024 |
Scope
To provide employees with guidelines to ensure the clubs legal obligations to have an Anti-Money Laundering and Counter Terrorism Financing Act.
Definitions
What is AML/CTF ACT?
- The AML/CTF Act is a federal law that requires clubs, hotels, casinos and TABS to make reports about large cash transactions or suspect transactions.
- Terrorism Financing is the act of providing financial support to terrorists or terrorist organisations to enable them to carry out terrorist acts.
- AUSTRAC is the government agency that receives reports of large and suspicious financial transactions.
- By reporting large transactions or suspicious activities we can help fight money laundering and terrorism financing.
Why do people launder money?
- To hide the profits made from illegal activities.
- Illegal drug dealing, arms smuggling, and other criminal activities related to organised crime can generate huge profits.
- The goal of these criminals is to conceal the profit they make out the illegal activity behind a legal front.
- Money laundering allows criminals to keep their ill-gotten profits and encourages further crime.
- Money laundering is often linked to the illegal drug trade.
- Money laundering may also be used by people smugglers, illegal prostitution rackets and corporate criminals.
Penalties for non-compliance
- Severe penalties apply for failure to comply with the AML/CTF requirements.
- Individuals can be fined up to $11 million or sent to prison.
- Non-compliance includes tipping off someone that they are being investigated for suspect activities.