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.
A New Era in Harm Minimisation: DNS Specialist Services and COMS Partner to Deliver Facial Recognition Technology
The gambling and entertainment industry continues to evolve, and with it comes a pressing responsibility: to prioritise harm minimisation and safeguard vulnerable patrons. At DNS Specialist Services (DNS SS), we have long recognised the importance of equipping venues and staff with the tools they need to meet this challenge. Today, we are proud to announce a new partnership with COMS, a trusted leader in operational solutions for the sector, to bring advanced Facial Recognition Technology (FRT) to the market. Why Facial Recognition Technology Matters Facial Recognition Technology has emerged as a critical tool in the global effort to support safer gambling environments. With the ability to identify excluded or at-risk individuals swiftly and discreetly, FRT provides staff with confidence and actionable insights to better manage harm minimisation responsibilities. This is not about surveillance, it is about protection, responsibility, and care. DNS SS and COMS: A Powerful Partnership DNS SS, under the leadership of Managing Director Danny Nixon-Smith who also serves on the Safer Gambling Advisory Committee and represents the industry across multiple jurisdictions brings deep expertise in harm minimisation, regulation, and industry standards. COMS complements this with its reputation for delivering robust, scalable, and user-friendly operational systems. Together, we are delivering solutions that don’t just meet compliance requirements but set new benchmarks for effectiveness and practicality in frontline operations. Supporting Staff in a Changing Landscape The gambling sector is experiencing rapid change, from heightened regulatory scrutiny to growing societal expectations. Staff are at the heart of this change, and they need the right tools to succeed. By integrating DNS SS’s industry insight with COMS’s technology platform, we are empowering venues with advanced, reliable, and ethical tools to meet their harm minimisation obligations head-on. Looking Ahead As this partnership evolves, our shared goal is simple: to continue innovating and supporting venues, staff, and communities in building safer gambling environments. Facial Recognition Technology represents the next step in this journey a step we are proud to take alongside COMS.
We’re Hiring – Marketing Manager
DNS Specialist Services is a consultancy firm dedicated to the Australian hospitality, gaming and leisure industries. We’re an energetic, passionate team who live and breathe hospitality. We pride ourselves on generating real outcomes for our pub, club and casino clients across QLD, NSW, VIC, TAS and NT – and with our portfolio growing rapidly, we’re ready to expand our leadership team. We’re looking for a Marketing Manager who can combine strategic thinking with hands-on marketing expertise, and who thrives on building relationships with clients while guiding a talented team to deliver great results. What you’ll be doing As a Marketing Manager, you will: This is not just a “make the posters and send the emails” role – it’s about consulting with clients, managing accounts, and steering strategy while still staying close enough to the creative to keep things fresh and fun. What you’ll bring What you can expect If you’re ready to step into a role where you’ll drive strategy, manage client relationships, and lead a growing marketing team, we’d love to hear from you. Send us your CV and a cover letter showing us why you’re the Marketing Manager we’ve been waiting for!
When Data Governance Becomes a Boardroom Challenge
In today’s digital-first environment, data is both the most valuable and the most vulnerable asset in the boardroom. Boards are increasingly tasked with overseeing not just strategy and performance, but also the governance of data, its use, security and ethical management. For many organisations, challenges around data significance and confidentiality remain hidden until a crisis emerges: a breach, a regulatory fine or reputational damage. At that point, the problem is no longer technical, it is strategic. Boards suddenly find themselves answering to regulators, stakeholders and the public. Why Boards Struggle With Big Data According to the Data Governance Foundations for Boards report, directors often underestimate the risks. The sheer speed at which data is generated makes oversight complex. Not all data is created equal, but without effective governance, critical data is treated the same as trivial information. Policies and procedures are too often written in response to incidents rather than as a preventative safeguard. On top of this, departing board members may still retain access to sensitive data and reports, exposing the organisation to long-term risks if proper offboarding is not in place. This mindset of “it is not a problem until it becomes a problem” remains one of the greatest challenges boards face. The Case for Proactive Planning A proactive approach ensures that boards do not simply react but lead. This means establishing clear policies and procedures that define roles, responsibilities and accountability. Regular audits should be conducted to identify vulnerabilities before they escalate. A culture of data stewardship needs to exist at both executive and operational levels, and governance must be aligned with both regulatory compliance and community expectations. Just as importantly, sensitive data must be secured during board transitions, ensuring that vacating members no longer retain access to reports, strategy documents or confidential datasets. How DNS Specialist Services Helps At DNS Specialist Services, we specialise in supporting boards to strengthen their governance and oversight. We provide independent data governance audits, assist in writing policies and procedures tailored to your business, and offer practical guidance to directors so that they can meet their obligations with confidence. We also implement secure offboarding protocols for vacating board members, ensuring that confidential information does not walk out the door. We do not just help you “tick the box”. We help you build a governance framework that reassures stakeholders, protects your organisation, and allows the board to focus on strategy with confidence. If your board has not yet addressed data governance at this level, the best time to act is now before it becomes a problem. Contact DNS Specialist Services today to start the conversation.
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.
Is Your Venue’s Marketing Feeling a Little… Flat? Let’s Talk Strategy!
Ever feel like your venue’s marketing is more of an afterthought than a game plan? You’re not alone. In hospitality, keeping the drinks flowing and the food hot is already a full-time job – so it’s no surprise that proactive marketing can take a back seat. But here’s the thing: even the best venues can struggle to attract new customers and keep regulars coming back if they don’t have a solid strategy in place.
Grow Your Own Hospitality Leaders
Finding hospitality staff with leadership or management skills can feel like searching for a needle in a haystack. Imagine walking into your venue and seeing your team effortlessly working together, solving problems on the fly, and delivering exceptional service. Sounds ideal, doesn’t it?
2025 Vision: Ignite Your Venue’s Success with a Strategic Plan
When was the last time you looked at your strategic plan, or is it tucked away in a drawer somewhere? Think of it as your venue’s annual service – are you ready to tune-up for a winning 2025 and beyond?
The hospitality landscape is a battlefield, with constant shifts in trends, evolving legislation and markets. It’s time to ditch the reactive approach and unite the key stakeholders to actively steer your venue towards prosperity.
Track your Club’s Strategic Plan, Agendas, Minutes & More with Board360
A challenge for many clubs is the lack of process for accountability on Strategic Plans and Corporate Governance. The Strategic Plan sits on a desk collecting dust, or on a shared server waiting to be saved over or accidentally deleted. Worse still, a new Board or Committee are appointed with no record of progress or discussions held.
Facing the Future: Navigating the Complexities of Facial Recognition Technology in Hospitality Venues
The recent Bunnings facial recognition controversy highlighted a critical gap in many organisations’ understanding and management of this powerful technology, particularly as many hospitality venues roll out the technology.
While facial recognition offers potential benefits for harm minimisation, its use raises significant ethical, legal, and reputational risks for venues. Failing to address these concerns can lead to hefty fines, damaged brand reputation, and eroded public trust.