Mounties allegations: AML in gaming sector not always a priority–but often poses high risk to AML/CTF
AUSTRAC, Australia’s financial intelligence unit, has launched Federal Court civil penalty proceedings against Mount Pritchard District and Community Club (Mounties). AUSTRAC alleges serious and systemic non-compliance with Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws.
AUSTRAC alleges that Mounties contravened the AML/CTF Act. They claim Mounties provided gaming services to its customers in circumstances where it had not adopted and maintained an AML CTF program in compliance with the AML/CTF Rules. AUSTRAC CEO Brendan Thomas said AUSTRAC alleges failures in Mounties’ approach to its anti-money laundering obligations have left it open to criminal exploitation.
“Mounties is one of the largest and most profitable club groups in NSW. It owns 10 venues, 8 of which operate approximately 1,400 poker machines. And it makes hundreds of millions of dollars in revenue from money gambled on those machines,” Thomas said.
Mounties allegedly allowed almost $140 million from just ten high-risk gamblers to flow through its poker machines between 2019 and 2024. Allegations claim the company lacked effective anti-money laundering and counter-terrorism financing (AML/CTF) controls.
The regulator’s allegations are serious. AUSTRAC accuses Mounties of failing to implement and maintain an AML/CTF program that met legislative requirements, neglecting to conduct proper risk assessments, and lacking adequate customer due diligence processes. The club allegedly had no effective transaction monitoring for its gaming machines, failed to train staff appropriately, and relied on a third-party compliance provider without exercising sufficient oversight.
According to Australia’s ABC News organization, AUSTRAC provided a sample of 10 gamblers it considered high risk of money laundering or counter-terrorism financing. Markers of suspicious activity included the following:
- Played the poker and slot machines (aka pokies) almost daily
- Gambled large sums, despite their personal and employment status
- Received a high number of or high value of payouts by check
- Deposited large sums of bank notes with minimal or no betting
- Handled money or tickets for other bettors
While Mounties did report some of the sample behavior, AUSTRAC describes the business’s compliance system as “not designed to enable Mounties to understand, recognize, identify, mitigate or manage the money laundering/terrorism financing risks posed.”
AML significance beyond the casino floor
While this case centers on a registered club with gaming operations, the underlying compliance failures mirror challenges seen in larger, more complex financial institutions. The high-value, high-frequency transactions; concentration of activity among a small group of high-risk customers; and lack of proactive detection measures are risk indicators that extend far beyond the gaming sector.
For regulators, this case is another reminder that AML/CTF obligations are not sector-optional — they apply to any entity handling large volumes of cash or facilitating potentially anonymous transactions. For compliance leaders, it underscores the need for end-to-end oversight, especially when outsourcing aspects of AML programs to third parties. Outsourcing compliance functions does not outsource accountability.
Why this matters for larger issuers and institutions
The Mounties case demonstrates how vulnerabilities at the point of transaction can allow vast sums of potentially illicit funds to move undetected. In larger issuers — such as banks, payment processors, or digital asset exchanges — the scale is even greater, and the systemic risk can be far higher. Whether it’s gaming machines or cross-border payment rails, the fundamental compliance questions remain the same:
- Do you know your customer — and their source of funds?
- Can your transaction monitoring detect unusual or concentrated activity in real time?
- Are escalation protocols clear, fast, and effective?
- Are you validating the quality and completeness of outsourced compliance work?
- Is your culture of compliance across your organization suitable to the risk for AML and terror financing in your enterprise?
The role of RegTech in closing these gaps
Cases like Mounties show why regulators increasingly expect institutions to leverage advanced technology to identify suspicious patterns faster and more accurately. Modern RegTech platforms — such as AML Partners’ RegTechONE — allow organizations to orchestrate data from multiple systems, apply dynamic risk rules, and monitor activity in near real time. The ability to configure detection scenarios without lengthy coding projects means institutions can respond quickly to emerging threats, regulatory changes, or shifts in criminal tactics.
A cautionary precedent
If proven, the allegations against Mounties could lead to significant financial penalties and reputational damage. For larger issuers, the lesson is clear: High-risk activity can occur in concentrated pockets, and without strong, technology-enabled oversight, it can remain hidden for years. The cost of discovering it only after a regulator does is measured not just in fines, but in lost trust, lost business, and long-term brand harm.
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