A keep-open notice ends by operation of law on the earlier of (i) the 6-month ceiling, or (ii) the day the issuing agency confirms the investigation has ended. Without an in-force Form 3 extension or AUSTRAC-CEO-approved further extension, the venue auto-resumes default CDD/EDD for the affected customer at the 6-month ceiling. The platform fires a 14-day pre-expiry reminder to the GM and records a forced-input decision artefact at every expiry transition.
Working draft, not legal advice
The plain-English summary above is drafted by Venue Axis as a navigation aid. The citation is the authoritative source — treat it as the definitive reference. For a legal interpretation of this obligation in your venue's context, talk to your counsel.
Holding keep-open mode beyond the 6-month ceiling without a Form 3 risks indefinite CDD suspension — incoherent with the AML/CTF Act's purpose. Auto-resuming too early risks tipping off the customer if an extension was issued but not yet received.
Consequences are summarised from the underlying legislation. Specific penalties depend on the breach pattern, prior history, and the regulator's enforcement posture. Talk to a liquor and gaming lawyer for a definitive view of your venue's exposure.
The venue must have a written AML/CTF programme document covering risk assessment, governance, training, independent review, and transaction…
The venue must conduct and document a money-laundering / terrorism-financing risk assessment covering customer types, designated services, d…
The governing body of the venue must approve the AML/CTF programme and document that approval.
The programme must be evaluated by an independent party (internal audit, external auditor, or consultant) at least once every three years, w…
Employees whose duties include AML/CTF obligations must receive appropriate training and the venue must maintain records of training complet…
Before providing a designated service above the threshold, the venue must identify the customer and verify their identity using reliable and…
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