AML compliance for bookmakers and betting agencies in Australia: Key Takeaways
- Bookmakers and betting agencies are already reporting entities under the AML/CTF Act and must comply with AUSTRAC’s core obligations for gambling service providers.
- The AML/CTF Amendment Act 2024 and reforms from March 2026 will shift AML/CTF programs away from box ticking and towards demonstrable, risk based controls for all reporting entities, including gambling operators.
- AUSTRAC has issued specific suspicious activity indicators for online betting agencies and on course bookmakers; these must inform your ML/TF risk assessment and transaction monitoring rules.
- Recent enforcement actions against casinos, clubs and online wagering operators show AUSTRAC will not hesitate to act where AML/CTF programs, customer due diligence or monitoring are weak.
- Effective AML compliance for bookmakers and betting agencies hinges on strong customer identification, risk based limits, targeted monitoring and clear escalation paths – without destroying the customer experience.
- Specialist AML and Tranche 2 consultants can help you uplift your risk assessment, redesign your AML/CTF program, tune monitoring rules, and prepare for AUSTRAC’s evolving expectations across the gambling sector.
Bookmakers and betting agencies sit on the frontline of financial crime risk in Australia. High volumes of fast moving bets, large cash transactions, VIP punters, online wallets and third party deposit channels all make the sector deeply attractive to criminals looking to clean or move funds.
AUSTRAC already regulates bookmakers, online wagering providers and other gambling services as reporting entities under the AML/CTF Act, because betting services and payouts are “designated services” in the gambling sector.
With the AML/CTF Amendment Act 2024 and the broader reform program, those obligations are being tightened and modernised from 2026. The focus is moving from “having a program on paper” to being able to show that your AML/CTF framework actually identifies, assesses and mitigates money laundering, terrorism financing and proliferation financing risk in practice.
AUSTRAC has also released specific sector guidance for bookmakers and betting agencies, including a dedicated page for the industry and suspicious activity indicators for both online betting agencies and on course bookmakers.
If you operate a wagering agency, on course bookmaking business, online sportsbook or hybrid retail and digital offering, you are very much in AUSTRAC’s line of sight.
The legal and regulatory framework for bookmakers
The AML/CTF Act and gambling as a “designated service”
AUSTRAC’s “Who and what we regulate” and “Bookmakers and betting agencies” pages make it clear that certain gambling activities are designated services under the AML/CTF Act. These include:
- accepting bets (for example by bookmakers and online betting agencies)
- providing betting accounts
- paying out winnings or awarding prizes in respect of bets or games of chance
- exchanging gaming chips, tokens or cash in connection with gambling.
If you provide these services in Australia, you are a reporting entity and must comply with AML/CTF obligations.
The AML/CTF Amendment Act and 2026 reforms
The AML/CTF Amendment Act 2024 updates and strengthens requirements for all reporting entities, including gambling operators. The Home Affairs overview emphasises that the new program obligations require entities to:
- focus on identifying, assessing and mitigating ML/TF/PF risk
- move beyond “check box” documents to risk based operational controls
- meet updated expectations for AML/CTF programs, customer due diligence and reporting.
Industry analysis indicates that key changes for existing gambling reporting entities are due to take effect from 31 March 2026, ahead of wider reforms affecting newly regulated Tranche 2 sectors.
For bookmakers and betting agencies, this means your AML/CTF settings need a hard, honest review now – not in 2026.
AUSTRAC guidance tailored to bookmakers and betting agencies
Several AUSTRAC resources are directly relevant to AML compliance for bookmakers and betting agencies:
- Bookmakers and betting agencies – sector specific core obligations and guidance.
- Gambling sector hub – decision tree for whether your gambling services are regulated.
- Indicators of suspicious activity for the online betting agencies sector – red flags tailored to online betting.
- Indicators of suspicious activity for the on course bookmaker sector – red flags for trackside operations.
- Worked examples for the online wagering industry – practical AML/CTF scenarios and responses.
- AML/CTF programs and Your obligations – cross sector guidance on program design, reporting and record keeping.
These are, in effect, AUSTRAC’s blueprint for what “good” looks like in AML compliance for bookmakers and betting agencies.
Core AML/CTF obligations for bookmakers and betting agencies
AUSTRAC summarises key obligations for all reporting entities as: enrolment, AML/CTF program, staff readiness, customer due diligence, reporting, and record keeping.
For gambling operators, those themes play out as follows.
Enrolment and registration
You must:
- enrol with AUSTRAC as a reporting entity providing gambling services
- keep your enrolment details (ownership, structure, key contacts) up to date
- register any remittance activities separately, if relevant.
AML/CTF program
Your AML/CTF program must be written, risk based and tailored to your betting business. AUSTRAC expects it to:
- set out governance, roles and responsibilities (including board and senior management oversight)
- describe how you identify, assess and mitigate ML/TF/PF risks
- detail your customer identification and verification procedures
- cover transaction monitoring, reporting and escalation
- specify record keeping, training and independent review arrangements.
Most operators structure this as Part A (governance and risk) and Part B (customer identification).
Customer identification and verification
The customer identification and verification obligation requires bookmakers and betting agencies to:
- collect and verify customer identity before providing designated services (subject to limited exceptions)
- identify and verify beneficial owners where accounts or betting activity are on behalf of entities
- risk rate customers based on product usage, betting patterns, source of funds and geography
- apply enhanced due diligence to higher risk customers and scenarios.
For online wagering, AUSTRAC expects robust digital identity verification and controls around pseudonyms, multi accounts and third party deposits, as highlighted in enforcement against major betting brands.
Ongoing due diligence and monitoring
Bookmakers and betting agencies must have systems to:
- monitor customer activity against expected betting behaviour
- detect unusual or suspicious patterns (for example, rapid in-and-out betting, low turnover with high deposits, use of cash deposit channels)
- review and update customer risk ratings
- investigate potential red flags and document the outcome.
AUSTRAC’s indicator lists for online betting agencies and on course bookmakers are specifically designed to inform these transaction monitoring scenarios and thresholds.
Reporting obligations
Gambling operators must submit:
- Suspicious Matter Reports (SMRs) where there is suspicion of ML/TF or other serious crime
- Threshold Transaction Reports (TTRs) for relevant large cash transactions
- International funds transfer reports (IFTIs) where applicable
- Compliance reports when required, summarising how the business is meeting AML/CTF obligations.
Recent AUSTRAC actions against casinos, wagering operators and clubs show that weak SMR practices and poor responsiveness to obvious red flags are a recurring enforcement theme.
Record keeping and staff readiness
You must keep records of:
- customer identification procedures
- betting and payout transactions
- SMR and other report decisions
- your AML/CTF program and risk assessment.
You must also ensure staff are trained and ready to implement your AML/CTF program, with training proportionate to their roles.
Money laundering and terrorism financing risks in betting
How bookmakers can be exploited
AUSTRAC’s gambling sector insights and national risk material highlight several ways that bookmakers and betting agencies can be misused:
- turning cash into betting credits and then withdrawing with little or no gambling (chip or credit cash-out)
- using betting accounts as de facto bank accounts to move value between individuals and entities
- placing bets with illicit funds and cashing out “winnings” as apparently legitimate gains
- wagering via intermediaries who place bets for criminal networks
- using accounts linked to high-risk offshore jurisdictions or entities.
AUSTRAC’s risk assessment for on course bookmakers concludes that accepting bets and paying out winnings present medium ML/TF vulnerability, especially where betting accounts are offered alongside trackside services.
Indicators of suspicious activity – online betting
AUSTRAC’s Indicators of suspicious activity for the online betting agencies sector list practical red flags that should inform your monitoring rules. Key themes include:
- Funding and withdrawal patterns
- large or repeated deposits followed by minimal or no betting, then rapid withdrawal
- heavy use of cash deposit channels or prepaid instruments.
- Account behaviour
- multiple accounts using shared contact details, devices or IP addresses
- frequent changes to identity or payment details without clear reason
- accounts seemingly controlled by third parties or groups.
- Customer profile
- reluctance to provide KYC information or attempts to circumvent verification
- links to adverse media, fraud, drugs, organised crime or tax evasion.
Indicators of suspicious activity – on course bookmakers
The on course bookmaker sector indicators highlight, for example:
- customers consistently betting in large cash amounts and cashing out early
- patterns of bets designed to minimise gambling loss while maximising turnover of funds
- use of associates or multiple people to place related bets or collect winnings
- patrons who move between bookmakers or venues, trying to avoid visibility.
Together, these AUSTRAC red flag lists form the backbone of risk based monitoring for AML compliance for bookmakers and betting agencies.
Best practices for AML compliance for bookmakers and betting agencies
Start with a robust, gambling specific risk assessment
Use AUSTRAC’s gambling hub, sector indicators and national risk assessments to map:
- customer segments (recreational, VIPs, high-net-worth, corporate, offshore)
- channels (online, retail, on course, pubs and clubs, agents)
- product types (sports betting, racing, in-play, multis, bet boosts, tote products)
- funding methods (cards, bank transfers, cash deposits, vouchers).
This risk assessment should not be a one-off document; it must drive your limits, monitoring scenarios, and enhanced due diligence triggers.
Strengthen onboarding and KYC
Good practice for bookmakers and betting agencies includes:
- electronic verification of customers wherever possible
- early capture of occupation, source of funds and expected betting profile for higher value or at-risk clients
- strict controls around multiple accounts, pseudonyms and third-party deposits
- robust beneficial ownership checks for corporate or syndicate accounts.
Use layered, risk based transaction monitoring
Combine AUSTRAC’s indicator lists with your own data to create:
- velocity rules (rapid deposits and withdrawals)
- turnover ratios (deposits versus actual betting activity)
- pattern detection (structured betting to minimise loss, mirror bets across accounts)
- channel controls (heightened monitoring for cash deposit networks and high-risk payment methods).
Work your alerts so that teams can focus on genuinely suspicious patterns rather than constantly clearing obvious false positives.
Align AML with responsible gambling and fraud
AML rarely sits alone. Many of the strongest gambling operators:
- integrate AML checks with fraud detection and responsible gambling systems
- share risk indicators between teams (for example, a sharp change in behaviour may trigger AML and RG review)
- ensure there is a single, coherent view of customer risk rather than three or four siloed risk assessments.
Manage outsourcing and third parties carefully
AUSTRAC’s guidance on using outsourcing to help meet your AML/CTF obligations is very clear: outsourcing does not remove your responsibility.
Recent actions against clubs and operators that relied heavily on third-party responsible gambling or AML providers underline that you must:
- conduct due diligence on vendors
- document who does what in contracts and your AML/CTF program
- actively oversee the outsourced activities and test their performance.
Challenges in implementing AML/CTF in betting businesses
From AUSTRAC commentary and sector analysis, common pain points for bookmakers and betting agencies include:
- Legacy systems and data fragmentation
Many operators run separate platforms for retail, online, loyalty and payments. Pulling this into a single AML view is hard work. - High volumes and low margins
The combination of high transaction volume and tight commercial margins makes it tempting to “set and forget” monitoring rules or delay remediation projects. - Complex customer networks
Syndicates, betting clubs and informal networks make it difficult to identify who really controls the activity and where the money comes from. - Regulatory change pressure
Reforms from 2026, plus ongoing AUSTRAC supervision and enforcement, mean compliance teams are under constant pressure to keep up. - Culture and accountability
Some gambling businesses still see AML as a cost centre. Without board level sponsorship and clear accountability, projects stall and control gaps remain open.
How AML consultants and Tranche 2 specialists can help gambling operators
Although bookmakers and betting agencies are not “Tranche 2” in the technical sense (they are already regulated), the same risk based mindset driving Tranche 2 reforms now applies to them. Consultants who live and breathe those reforms can be invaluable.
On this firm’s blog, it is only fair to be direct about how we typically help clients with AML compliance for bookmakers and betting agencies:
Risk assessment uplift
- Review and rebase your ML/TF/PF risk assessment using AUSTRAC’s gambling risk insights, bookmaker indicators and online wagering examples.
- Align your risk ratings with actual behaviour, product mix and payment channels.
AML/CTF program redesign for the 2026 reforms
- Update your AML/CTF program to meet the Amendment Act requirement for a truly risk-based framework.
- Build clear policies and procedures for both online and on-course operations, and for relationships with pubs, clubs and agents.
Transaction monitoring tuning and alert optimisation
- Re-calibrate rules to reflect AUSTRAC’s latest indicators for the online betting and on course bookmaker sectors.
- Reduce noise while increasing your ability to spot genuine ML/TF patterns.
Remediation and regulatory engagement
- Support targeted look backs and enhanced file reviews where AUSTRAC has raised concerns.
- Help you prepare documentation, data and narrative for supervisory visits or enforcement discussions.
Training, culture and board reporting
- Deliver tailored training for board, executives, trading teams and frontline staff.
- Build reporting packs that give leadership a clear line of sight over AML risks and remediation activity.
Done well, AML compliance for bookmakers and betting agencies does not just keep AUSTRAC satisfied. It protects your licence, your brand and your long term ability to operate in what is fast becoming one of the most heavily scrutinised sectors in Australia.
“Bookmakers sit at a natural convergence point for cash, speed and anonymity. AUSTRAC’s focus reflects the reality that wagering platforms can be misused as value transfer mechanisms if risk controls are not actively applied.”
FAQs -AML compliance for bookmakers and betting agencies
1. What is AML compliance for bookmakers and betting agencies in Australia?
AML compliance for bookmakers and betting agencies means meeting all obligations under the AML/CTF Act and Rules as gambling service providers. This includes having a risk based AML/CTF program, identifying and verifying customers, monitoring betting activity, reporting suspicious matters and threshold transactions to AUSTRAC, and keeping appropriate records.
2. Are bookmakers and betting agencies part of Tranche 2?
No. Bookmakers and betting agencies are already regulated reporting entities under the AML/CTF Act as gambling service providers, not as newly captured Tranche 2 DNFBPs. However, the same reform package that introduces Tranche 2 for other sectors also tightens the program and risk requirements for existing gambling entities from 2026.
3. What AUSTRAC guidance is most relevant to betting operators?
Key AUSTRAC resources for AML compliance for bookmakers and betting agencies include: the Bookmakers and betting agencies industry page; the gambling sector hub; Indicators of suspicious activity for the online betting agencies sector; Indicators of suspicious activity for the on course bookmaker sector; Worked examples for the online wagering industry; and cross sector guides on AML/CTF programs and Your obligations.
4. What are common red flags for money laundering in betting?
Common red flags include large or repeated deposits with minimal betting and quick withdrawals, heavy use of cash deposit channels, multiple accounts linked by common details, third party account control, betting patterns designed to minimise gambling loss while recycling funds, and customers with known criminal associations or adverse media. AUSTRAC’s suspicious activity indicators for the online betting and on course bookmaker sectors give detailed examples.
5. What reports must bookmakers and betting agencies lodge with AUSTRAC?
Betting operators must lodge Suspicious Matter Reports when they suspect ML/TF or other serious crime, Threshold Transaction Reports for certain large cash transactions, international funds transfer reports where applicable, and compliance reports when requested by AUSTRAC.
6. How do the 2026 reforms change AML requirements for gambling operators?
From March 2026, the AML/CTF Amendment Act and AUSTRAC reforms will require gambling operators to demonstrate an AML/CTF program that is genuinely risk based, with a sharper focus on ML/TF/PF risk identification, assessment and mitigation. This includes stronger expectations around risk assessments, CDD, transaction monitoring and governance, and is part of a broader uplift across all reporting entities.
7. Do small on course bookmakers and niche betting agencies still need a full AML/CTF program?
Yes. All reporting entities that provide designated gambling services must have an AML/CTF program, regardless of size. AUSTRAC permits a proportionate approach – so smaller, lower risk operators can adopt simpler processes – but they must still cover risk assessment, customer identification, monitoring, reporting and record keeping in a way that is effective for their business.
8. How can AML consultants help with AML compliance for bookmakers and betting agencies?
Specialist consultants can help by uplifting your risk assessment, redesigning your AML/CTF program for the 2026 reforms, tuning transaction monitoring rules to AUSTRAC’s latest indicators, supporting remediation and look backs, training staff and preparing board and AUSTRAC facing documentation. This allows you to meet regulatory expectations and reduce enforcement risk while keeping your focus on running a competitive, sustainable betting business.
