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Worked examples for the online wagering industry

How to use these examples

These examples are designed to help the online wagering industry better understand and meet anti-money laundering and counter-terrorism financing (AML/CTF) compliance obligations.

They can be used as a guide to help you understand how you can apply a flexible approach to activities that may be carried out by a customer. This includes customer requests to withdraw funds from their wagering account after minimal or no gaming turnover of those funds for gambling purposes.

You should consider how you may apply these examples in the context of your business’s own risk profile.

What is an online wagering operator?

For the purposes of these examples, online wagering operators are businesses licensed by a State or Territory to provide an online gambling service such as sports betting. These online gambling services do not include online poker or online casino games.

Processes and procedures vary between different businesses, and not all components of the examples will apply to all online wagering operators. However, they may help you decide when to apply similar actions to customer behaviour which is not specifically included in the examples here.

Terminating customer accounts

In some examples, the online wagering operator provides a suspicious matter report (SMR) to AUSTRAC, however the example does not specify whether the operator terminates the customer’s account. This is because the decision to close an account is a matter for you to determine, consistent with your business’s risk based approach. This decision should be informed by a number of factors, including the outcome of enhanced customer due diligence.


The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.

Last updated: 12 Nov 2020
Page ID: 560

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