Navigating the Evolving Landscape of Harm Minimisation and AML/CTF in Hospitality

The goalposts are shifting for pubs and clubs when it comes to harm minimisation and preventing financial crime. With AUSTRAC’s 2026 AML/CTF reforms on the horizon, venues are facing a significant overhaul in how they approach risk management, customer due diligence, and ongoing monitoring. This isn’t just about ticking boxes; it’s about building a robust, tailored framework that protects your patrons, your business, and your reputation.

The upcoming changes, rolling out from March 31, 2026, and further in July 2026, demand a proactive stance. AUSTRAC is clearly signalling heightened scrutiny, particularly around large cash transactions, electronic gaming machine activity, and the ongoing monitoring of high-risk individuals. We’ve all seen the headlines – the substantial penalties imposed on major players like Crown Casino and the ongoing proceedings against others. The message is clear: the stakes are higher than ever.

So, what does this mean for you?

A Deeper Dive into Due Diligence and Risk

The reforms are bringing a more thorough way of getting to know your customers. While the requirement to identify customers for transactions above $10,000 will shift down to $5,000 in 2029 (lining up with international guidelines), the immediate focus is on a two-step process. First, you’ll need to identify and assess the risk of a patron before they use your services. Then, there’s ongoing observation throughout your relationship with them. It’s all about really understanding your patrons, gauging their risk level, and responding appropriately. For those who are lower risk, the process can be simpler, but for higher-risk individuals – such as foreign public officials or anyone showing suspicious behaviour – you’ll need a more detailed approach.

Your AML/CTF Program itself will need a significant refresh. Gone are the days of generic templates. AUSTRAC now expects a truly risk-based approach, where your program specifically addresses the unique money laundering and terrorism financing risks inherent to your venue, your customer base, and your operations. This requires a thorough risk assessment that goes beyond a superficial overview.

Technology as a Partner in Harm Minimisation

This is where innovative solutions prove incredibly valuable. Beyond strengthened AML/CTF programs, advanced facial recognition technology (FRT) is a powerful tool for elevating harm minimisation and compliance. Venues are now able to proactively identify individuals who have self-excluded or those known to pose a risk to themselves or others – moving from reactive measures to informed, early intervention.

DNS Specialist Services is proudly partnering with Coms Detect, bringing cutting-edge FRT solutions that integrate seamlessly into your venue’s existing security infrastructure. This partnership highlights our unwavering commitment to harm minimisation, providing technology that precisely assists in identifying individuals of interest and empowering your staff to intervene earlier and more appropriately. It’s not about negative surveillance; it’s about equipping your team with the essential tools to foster a safer environment and to more effectively uphold your social responsibility obligations. This proactive identification is a true game-changer in managing risk and ensuring unwavering compliance, helping venues navigate the evolving regulatory landscape and set new standards for patron safety.

Staying ahead of the 2026 reforms and truly enhancing your harm minimisation efforts requires proactive planning and the right partnerships. Ensure your venue is not just compliant, but also operating at the forefront of patron safety.

DNS Specialist Services provides the expertise and solutions you need. Explore our full range of AML/CTF audit and review services, and discover how our partnership with Coms Detect can strengthen your approach to harm minimisation.

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