AML/CTF Act 2006 (Cth)

PEP screening — three-tier framework

Cth · AUSTRACDoes (triggered)

The Rules establish a three-tier PEP framework: foreign politically exposed person (always triggers enhanced CDD); domestic politically exposed person (triggers enhanced CDD only where ML/TF risk is high); international organisation politically exposed person (same treatment as domestic). For each PEP, the venue must establish on reasonable grounds the source of the PEP's wealth and the source of the PEP's funds. A foreign PEP who has ceased the position for ≥12 months is treated as a domestic PEP (s.6-23(3)) for the purposes of initial CDD where their status arises from the same foreign country.

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.

Operational metadata

How this obligation operates.

Citation
AML/CTF Rules 2025 (Cth) (F2025L01026) Part 6 Division 5 — Politically exposed persons; Rules 6-23 (initial CDD) and 6-24 (ongoing CDD); read with AML/CTF Act 2006 (Cth) ss.28, 30, 32 and Rule 1-5 (PEP definitions; "domestic PEP" at the local-government layer is limited to the head of a local government council, not all councillors)
Read on legislation.nsw.gov.au →
Frequency
On event
Binds
rgo, gm, ceo, venue
Strategic tier
Does (triggered)
Venue Axis initiates the regulatory action when conditions are met — e.g. TTR or SMR pipelines triggered at thresholds, escalation dispatch, MVSE breach cross-venue notification.
Consequence of breach

What can go wrong.

Civil penalty for failing to apply enhanced CDD to a foreign PEP, or for failing to apply it to a high-risk domestic/international-organisation PEP. Senior-manager approval is required where a previously-PEP customer continues to receive designated services per Rule 6-23(5) (programme requirement).

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.

Related obligations

Other items in AML/CTF Act 2006 (Cth).

Does (enforced)

Maintain a documented AML/CTF programme (Part A)

The venue must have a written AML/CTF programme document covering risk assessment, governance, training, independent review, and transaction

Does (enforced)

Periodic ML/TF risk assessment

The venue must conduct and document a money-laundering / terrorism-financing risk assessment covering customer types, designated services, d

Does (enforced)

Board approval of AML/CTF programme

The governing body of the venue must approve the AML/CTF programme and document that approval.

Supports

Independent evaluation of AML/CTF programme

The programme must be evaluated by an independent party (internal audit, external auditor, or consultant) at least once every three years, w

Does (triggered)

AML/CTF staff training

Employees whose duties include AML/CTF obligations must receive appropriate training and the venue must maintain records of training complet

Does (enforced)

Customer Due Diligence at enrolment

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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