The Mounties Wake-Up Call: Three Questions Every Board Should Be Asking
The Federal Court action AUSTRAC has launched against Mounties Group in a watershed moment for the hospitality industry. This isn’t just another regulatory breach; it’s a signal that should command the full attention of every Board and General Manager. When an organisation of that scale faces allegations of systemic failure, it proves no one is too big to be scrutinised. This heightened scrutiny isn’t happening in a vacuum. It’s a direct response to a well-documented national issue. The NSW Crime Commission’s estimate – that billions in illicit funds are washed through poker machines annually – provides all the context needed. The era of passive compliance is officially over. The new standard is demonstrable, active oversight. This new reality demands a shift in focus, prompting leadership teams to look inward and ask some tough questions across three critical areas of their operation. 1. Your AML/ CTF Program: Is It a Strategic Asset or a Delegated Task? Many venues rightly engage external experts to develop their AML/CTF program. The danger isn’t in the outsourcing of its creation, but in the outsourcing of its ownership. A program that is developed, delivered, and then left on its own becomes a significant liability. The Board and executive team are ultimately accountable. Do you genuinely understand the mechanics and commitments detailed within your program, or are you operating on the assumption that it’s simply being handled? Regulators now expect leadership to articulate their program’s strategy, not just defer to a consultant. 2. Your Risk Assessment: Is It a Snapshot in Time or a Living Document? A risk assessment is not a one-off event to be ticked and filed. Criminal threats, regulatory requirements, and even your own business operations are in constant flux. An assessment conducted last year may not accurately reflect your risk profile today. The crucial question is this: is your leadership team actively monitoring these changes and adapting your strategy accordingly? Regulators expect to see a continuous loop of assessment, adaptation, and action. A static risk assessment is a historical record; a dynamic one is a vital governance tool. 3. Your People: Is Your Team Trained, or Are They Truly Confident? A technically perfect program is useless if it’s not executed effectively on the floor. While staff training is a key component, the real metric is confidence. On a busy Saturday night, is your team – from gaming attendants to management – truly confident in their ability to identify and report suspicious matters? Or is there a culture of hesitation, a fear of getting it wrong, or a simple lack of clarity that creates an execution gap? This gap between policy and practice is where a compliance framework most often fails. The immediate lesson from this landmark case is that the definition of compliance has fundamentally shifted. It’s no longer about possessing the right documents, but about proving that active management and leadership accountability are embedded in your venue’s culture. If these questions create uncertainty, it’s a sign that a deeper review is needed. Let’s work together to ensure you are ready for the day AUSTRAC comes knocking. Connect with us for a confidential review of your AML/CTF framework or conduct a complete Harm Minimisation Program Audit.