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Lessons From Crown's Latest Crisis

As seen in the April 2021 edition of Bowls Queensland's Queensland Bowler magazine.

Whether you're talking about the latest season in a popular Netflix drama or Harry and Meghan's interview with Oprah, one thing's for sure - the last few months have been a rollercoaster for the Crown. Things haven't been easy for the 'other' Crown either, following the NSW Independent Liquor and Gaming Authority's (ILGA's) recommendation to revoke a certain Sydney casino licence.

The topic of money laundering is back in the spotlight after ILGA found that Crown Resorts is unfit to hold a NSW casino licence, due to concerns that senior management at Crown had failed to understand and comply with anti-money laundering laws at their Melbourne and Perth casinos.

But issues of money laundering are by no means restricted to casinos. The NSW government estimates that around 20% of money put through gaming machines in NSW relates to organised crime, and there is now a new push for gaming machines to be made cashless, with an electronic gaming card, designed to make money laundering more difficult.

The Australian Transaction Reports and Analysis Centre (AUSTRAC) have identified clubs as vulnerable targets for money laundering, and all Bowls Clubs with gaming machines should be aware of their anti-money laundering reporting and compliance obligations.

Four important tips are:

  • Conduct a risk assessment and develop a tailored anti-money laundering program to fit your Club. Clubs must have a program in place to address the way you will respond to money laundering and the associated risks, such as by appointing a compliance officer, developing a staff training program, setting out your procedures for monitoring transactions, reporting suspicious activity, and subjecting your program to independent reviews.
  • Criminals are often willing to lose a percentage of their money as a cost of money laundering. Indeed, money laundering can still occur even when a patron plays all the money they deposit. Therefore, effective transaction monitoring programs should identify customers who receive a high number of gaming payouts over a specific period.
  • A person engaged in money laundering may become a regular patron of your club. While it is important to build strong relationships with customers, your staff should also be vigilant and constantly monitoring for suspicious activity. Examples include patrons buying winning tickets from another customer with cash, asking for cheques to be written in someone else’s name, producing false identification or being reluctant to use identification, and bringing large amounts of cash to gamble, especially where the cash is not withdrawn from on-site ATMs and/ or where this seems beyond the person's means.
  • Bowls Clubs have specific record keeping obligations under federal anti-money laundering laws. It is critical for your Club to maintain accurate records of transactions, and preferably, to keep these records electronically so that transactions can be monitored more easily.

Suspicious matters should be reported to AUSTRAC within 24 hours if your suspicion relates to terrorism financing, or within three days if your suspicion relates to money laundering or other crimes.  Reports can be submitted via AUSTRAC online and there are no adverse consequences for your Club, or the customer, if no criminal activity is found. On the other hand however, clubs can be fined if they do not have a compliant anti-money laundering program in place and/ or, if they do not report suspicious matters in their venues.

Should you have any questions about money laundering, or if you require assistance in developing an anti-money laundering program, please give me a call on 07 3224 0353.

Article written by Matthew Bradford (Partner) and Glen Rolley (Associate).

"The content of this publication is for reference purposes only. It is current at the date of publication. This content does not constitute legal advice and should not be relied upon as such. Legal advice about your specific circumstances should always be obtained before taking any action based on this publication."