Uplifting the AML/CTF program at a NSW registered club
A NSW registered club needed its AML/CTF program brought up to standard.
The brief
Registered clubs carry the same AML/CTF obligations as other regulated entities, but rarely have the dedicated compliance resourcing that larger regulated sectors take for granted - the program often develops in pieces, as obligations are added, rather than as one coherent whole. Uplift the club’s AML/CTF program so its policies, monitoring and governance meet its compliance obligations, and would hold up under genuine regulator and internal-audit scrutiny, not just a paper review.
Our approach
We worked through the full policy suite in turn, checking each element against both current obligations and what the club was actually doing in practice, not just what its policies said it should do - customer screening and risk assessment, transaction monitoring, enhanced oversight of patrons and loyalty tiers, unusual-activity reporting, and personnel due diligence. Strengthening the suite meant closing the gaps between documented policy and daily practice, not just rewriting the documents. On top of the uplifted policy suite, we produced a money-laundering and terrorism-financing risk assessment built on the club’s actual risk profile, and prepared reporting for the board committee so oversight of the program sat with the board on an ongoing basis, not just at review time.
The outcome
An uplifted AML/CTF program, with a completed risk assessment and board-committee reporting now in place. The club has a program built to withstand scrutiny rather than pass a paper check, and a board with the ongoing visibility it needs to stay confident the program keeps pace with its obligations.
