- Overview and Purpose
This document sets out the Anti-Money Laundering (AML) and Know Your Customer (KYC) policy applicable to Wrest Point Casino. The policy establishes the obligations of Wrest Point Casino and its customers in relation to identity verification, transaction monitoring, suspicious matter reporting, and record-keeping, in accordance with Australian law and the requirements of the Australian Transaction Reports and Analysis Centre (AUSTRAC).
Wrest Point Casino operates as a licensed casino in Tasmania, Australia. As a reporting entity under Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), Wrest Point Casino is required to maintain a compliant AML/CTF program, conduct customer due diligence, monitor transactions, and report specified matters to AUSTRAC.
This policy applies to all customers, guests, and account holders who engage in gaming or related financial transactions at Wrest Point Casino.
- Legal Framework
Wrest Point Casino’s AML and KYC obligations are governed by the following:
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)
- Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (Cth)
- AUSTRAC guidance applicable to casino operators
- Tasmanian state gaming legislation and licence conditions
- Financial Action Task Force (FATF) recommendations, to the extent adopted under Australian law
Where any conflict arises between this policy and applicable law, the applicable law prevails.
- Customer Identification and KYC Requirements
3.1 Identity Verification
Wrest Point Casino is required to verify the identity of customers in circumstances prescribed by the AML/CTF Act and associated rules. Identity verification may be required at the time of account creation, membership enrolment, cage transactions, or when a customer engages in a transaction that triggers a reporting or due diligence obligation.
Customers may be required to provide the following information and documentation:
- Full legal name
- Date of birth
- Residential address
- Government-issued photographic identification (such as a passport or driver’s licence)
- Additional documentation as required by the nature or value of the transaction
Wrest Point Casino reserves the right to request identity documents at any point where a legal obligation to verify identity arises, or where the casino’s internal risk assessment indicates that verification is necessary.
3.2 Age Verification
All customers must be of legal gambling age under Tasmanian law before being permitted to engage in gaming activities. Wrest Point Casino verifies age as part of the standard identification process. Entry to gaming areas and participation in gaming activities is refused where age cannot be confirmed.
3.3 Enhanced Due Diligence
For customers identified as high-risk, high-value, or politically exposed persons (PEPs), Wrest Point Casino applies enhanced due diligence measures. These measures may include:
- Source of Funds (SOF) assessment to confirm the origin of funds used for gaming
- Source of Wealth (SOW) assessment to confirm the broader financial background of the customer
- Ongoing monitoring of transactions and gaming behaviour
- Additional documentation requests
- Escalation to the casino’s compliance function for review and decision
Enhanced due diligence is applied on a risk-based basis and is not limited to any single transaction type or value.
- Transaction Monitoring and Reporting Obligations
4.1 Threshold Transaction Reports
Wrest Point Casino is required to submit a Threshold Transaction Report (TTR) to AUSTRAC for any cash transaction of A$10,000 or above conducted within a single gaming day. This obligation applies regardless of whether the transaction is a single payment or a series of related transactions that together meet or exceed the threshold.
Structuring transactions to avoid the A$10,000 reporting threshold is prohibited under Australian law. Wrest Point Casino monitors for structuring behaviour and reports suspected structuring to AUSTRAC.
4.2 Suspicious Matter Reports
Wrest Point Casino is required to submit a Suspicious Matter Report (SMR) to AUSTRAC where there are reasonable grounds to suspect that a transaction or activity is related to:
- Money laundering or proceeds of crime
- Financing of terrorism
- Tax evasion or other financial crime
- Any other matter that gives rise to a suspicion under the AML/CTF Act
There is no minimum monetary threshold for an SMR obligation. Wrest Point Casino’s compliance function is responsible for assessing suspicious matters and determining whether an SMR must be filed. This determination is made independently of any commercial or revenue considerations.
Customers are advised that Wrest Point Casino is prohibited by law from disclosing to a customer or any third party that an SMR has been or may be submitted in relation to that customer’s activity (tipping-off prohibition).
- Record-Keeping
Wrest Point Casino retains records relating to customer identification, due diligence, and transaction monitoring for a minimum period of seven years from the date the record was created or the transaction was completed, in accordance with AML/CTF Act requirements. Records are maintained securely and are made available to AUSTRAC or other authorised regulatory bodies upon lawful request.
- AML/CTF Program and Compliance Function
Wrest Point Casino maintains a written AML/CTF program that includes:
- Internal policies, procedures, and controls to manage money laundering and terrorism financing risk
- A designated AML/CTF compliance officer responsible for overseeing the program
- Regular independent testing and audit of AML/CTF controls
- Ongoing staff training on AML/CTF obligations and suspicious matter identification
- A risk-based customer due diligence framework
- Procedures for escalation, reporting, and documentation of compliance decisions
The AML/CTF compliance function operates independently of business development and revenue functions to ensure that compliance decisions are not influenced by commercial interests.
- Customer Obligations
Customers of Wrest Point Casino are required to:
- Provide accurate and complete identity information when requested
- Produce valid identity documents upon request by casino staff or the compliance function
- Cooperate with any due diligence process initiated by Wrest Point Casino
- Refrain from structuring transactions to avoid reporting thresholds
- Refrain from using Wrest Point Casino facilities for any purpose connected with money laundering, terrorism financing, or other financial crime
Failure to comply with these obligations may result in refusal of service, suspension or termination of membership, and reporting to AUSTRAC or other relevant authorities.
- Use of Customer Information
Personal information collected by Wrest Point Casino for AML and KYC purposes is used solely for the purposes of meeting legal compliance obligations, conducting due diligence, and fulfilling reporting requirements. Such information is handled in accordance with Wrest Point Casino’s Privacy Policy and applicable Australian privacy legislation.
Customer information collected under this policy may be disclosed to AUSTRAC, law enforcement agencies, or other regulatory bodies where required by law.
- Policy Review
This policy is reviewed periodically to ensure ongoing compliance with applicable Australian AML/CTF legislation, AUSTRAC guidance, and FATF standards as adopted in Australia. Updates to this policy take effect from the date of publication on Wrest Point Casino’s official channels.