On 30 July 2025, we initiated proceedings against the Mount Pritchard District and Community Club Limited, Mounties, for alleged contraventions of the Anti-Money Laundering and Counter Terrorism Financing Act 2006. This case underscores the seriousness of compliance and highlights the role consultants can play in helping businesses meet their AML/CTF obligations. 

Read the concise statement of the Current Court Proceedings. 

Setting the scene

The case responded to our engagement in the sector, including:

• the release of the Pubs and Clubs Regulatory Guide in 2021
• a supervisory campaign in 2022 into the industry involving educative visits at 247 venues across the country
• a more intensive High Risk Venue campaign, where entities providing electronic gaming machines were subject to compliance assessments.

Our engagement with the sector coincided with the publication of the NSW Crime Commission Project Islington report, which provided an in-depth analysis of money laundering risks in pubs and clubs. 

Why the Mounties case matters

Our action against Mounties demonstrates our ongoing focus on money laundering risks in pubs and clubs and the broader gambling sector. This has been a regulatory priority since 2024. The proceedings follow a series of enforcement actions, including civil penalty proceedings initiated against casinos and bookmakers in recent years. 

The allegations against Mounties highlight the importance of reporting entities maintaining AML/CTF programs that are tailored and appropriate to the size, nature and complexity of their operations. This also requires that the key pillars of an AML/CTF program, including risk assessment, transaction monitoring program and customer due diligence, are effective in their design and execution having regard to the risks a business faces. 

The role of consultants

It is entirely appropriate and sometimes necessary for reporting entities to engage consultants to assist them in fulfilling aspects of their AML/CTF obligations.

AML CTF advisers can:

• build your understanding of the ML/TF risks facing your sector and your business
• provide advice on your AML/CTF obligations
• provide expertise on risk management and regulatory requirements
• assist you to develop a tailored money laundering and terrorism financing risk assessment for your business
• assist you to develop a tailored AML/CTF program for your business
• train your staff on AML/CTF matters
• conduct independent reviews of your AML/CTF.

However, the ultimate responsibility in the provision of designated services rests with the reporting entity. Boards and other senior managers should be asking questions to determine whether money laundering risks are being effectively identified, managed and mitigated, regardless of whether a consultant is engaged or those risks are being managed in house. 

Our guidance on third-party advisers

We have issued guidance for reporting entities who use third party advisers, including key questions to ask when engaging external providers, such as:

• What AML/CTF and risk management qualifications and experience do they have?
• Do they understand the regulatory framework and stay up to date with the changes?
• Do they have strong knowledge of your sector and how it might be vulnerable to ML/TF risks?