Indicators of suspicious activity for pubs and clubs

If you suspect that a customer or transaction is linked to a crime, you are required to submit a suspicious matter report to AUSTRAC.

This list of indicators will help you identify potential money laundering, terrorism financing and other serious and organised criminal activity involving electronic gaming machine (EGM) venues.

On its own, one of these indicators may not suggest suspicious activity however, you should conduct further monitoring and examination. When you identify suspicious activity you should conduct enhanced customer due diligence in line with your AML/CTF program.

The list is not exhaustive and you should consider other indicators specific to your business’s  risk profile and circumstances.

AUSTRAC has a suspicious matter reporting reference guide and a suspicious matter reporting checklist to help you ensure your SMRs are effective.

Avoiding Identification procedures

  • Customer provides a false or altered identification document (ID)
  • Customer is reluctant to provide ID, and asks staff to refer to information or ID previously provided/on-file
  • Customer repeatedly collects winnings just below the thresholds for mandatory ID collection
  • Customer makes an unusual enquiry to venue staff about whether they report to government authorities or more specifically to AUSTRAC, the tax office or law enforcement agencies
  • Customer advises they have no ID and requests winnings be paid by cash to the threshold amount, and never return to collect the balance by cheque (some states allow part payment up to cash limit and balance by cheque)

TITO tickets and CRT receipts

  • Customer approaches a person at an EGM and offers to purchase their ticket in ticket out (TITO) ticket or the credit on their EGM
  • Customer photographs their TITO ticket so they can later rely on it to justify receipt of funds
  • Customer requests to take a photograph of another customer’s TITO ticket so they can later rely on it to justify receipt of funds
  • Customer plays an EGM then saves cash redemption terminal (CRT) receipts so they can later rely on them to justify receipt of funds
  • Customer requests any redeemed TITO tickets or CRT receipts from venue staff


  • Customer feeds an EGM with cash and requests a cheque or electronic funds transfer (EFT) payment after no, or minimal, play
  • Customer feeds an EGM with cash and requests a cheque or EFT payment for amounts under the non-cash threshold after minimal or no play
  • Customer attempts to have funds directed to a third party such as another person or a company
  • Customer supplies a third-party’s BSB and account number, along with their own account name, to effect a payment to a third-party without detection
  • Customer states they don’t have a bank account and insists on receiving cash
  • Customer offers venue staff a small gift or bribe to not record any details of a cheque or EFT payment
  • Customer advises venue staff they have a ‘cash business’ and asks to exchange cash for cheques
  • Customer presents a combination of TITO tickets and cash, asking to exchange them for a cheque
  • Customer presents multiple TITO tickets to exchange for a cheque
  • Customer asks for multiple TITO tickets under the cheque threshold to be paid as a cheque

Customer behaviour

  • Individual EGM hoppers have large sums of cash inserted but records indicate minimal or no play
  • Customer tries to circumvent note insertion limits by playing multiple EGMs at once, sometimes non-adjacent EGMs
  • Customer attempts to influence a new staff member to ignore their suspicious activity, including by offering tips
  • Customer only deals with one venue staff member and avoids other staff
  • Customers with no known relationship sharing funds
  • Customer has large sums of cash, with indications they have recently been involved in a serious crime, e.g. they are wearing an electronic tracking device
  • Customer abandons an EGM and fails to request a payout once credits are to a value greater than the cheque/EFT payment threshold amount
  • Customer plays EGMs at a venue far from the home address listed on their ID or their known place of business
  • Customer who regularly uses a loyalty card suddenly doesn’t use it and appears to have significant winnings
  • A law enforcement agency makes enquiries to a venue about a customer’s gaming activity
  • A venue staff member informs a customer that AUSTRAC or a law enforcement agency have or will be visiting the venue


  • Customer sells a cheque issued by a venue to a broker and then returns to the venue advising they have lost the cheque and requires a replacement
  • Customer alters the name of the payee of a cheque or changes the dollar amount to a higher value

Counterfeit notes

  • Customer attempts to use counterfeit notes to credit an EGM
  • Customer’s banknote is rejected by an EGM or CRT as the note is identified as being counterfeit
  • Customer asks the cashier to change banknote denominations instead of using a CRT with a counterfeit note scanner
  • Customer asks to change banknote denominations for odd reasons, e.g. because they are a collector seeking a specific note serial number or series

Know your customer information

  • Customer is identified as a politically exposed person, or linked to one
  • Customer is linked to adverse, crime-related media
  • Customer is matched through screening against an Australian or international sanctions list
  • Customer is a member of, or linked to, a known terrorist organisation
  • Customer’s source of wealth or source of funds is unexplained and/or inconsistent with their profile
  • Customer’s source of wealth and source of funds indicates they are linked to a business in an industry known for being cash-intensive. Therefore, EGM play/cashing out for a cheque or EFT payment may indicate they are putting the business’ gross takings through EGMs to avoid paying tax

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: 30 Mar 2023
Page ID: 947

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