An independent AML/CTF review across a multi-venue club group
A multi-venue NSW club group needed an independent view of its AML/CTF program across every venue, not just one site.
The brief
A group operating several venues carries a particular AML/CTF risk: each venue can end up interpreting the same obligations slightly differently, creating inconsistent practice and blind spots that only show up when someone looks across the group rather than at any one site. Evaluate the AML/CTF program consistently across the group, with a clear-eyed view of what to fix first, so leadership had one picture of the group’s real risk position rather than three separate, potentially conflicting opinions.
Our approach
We ran on-site reviews across three venues using a structured methodology, starting with a data and information register at each site - establishing what actually existed venue by venue before assessing any of it, so the findings were built on a consistent factual base rather than each reviewer’s on-the-day impression. From that shared base, we ran a detailed compliance assessment identically across all three venues, so results were genuinely comparable site to site rather than three independent reviews stitched together after the fact.
The outcome
A full set of findings and a prioritised recommendations register, ranked by ease of implementation and long-term relevance, giving the group a clear order of operations. Rather than facing an undifferentiated list of gaps across three venues, group leadership can now sequence remediation deliberately - addressing what matters most and is fastest to fix first, and building toward the longer-term changes from a position of early, visible progress.
