Indeed, the Australian Parliament is aware of such. There is no doubt poker machines and other forms of gambling provide a relatively easy vehicle by which to launder money.
If a criminal were to use poker machines at their local pub, club or casino to launder money, then those criminals may enjoy a curious lacuna in the application of the law.
Other more probable (it is suggested) laundering methods lack this level of regulatory coverage. Gambling is one such area. Such an improbable (it is suggested) method would not only be caught by legislation, it is also the subject of specific AUSTRAC policy (AUSTRAC, Financial crime guide – Stopping the illegal trafficking of Australian wildlife (2020)). For example, suppose a criminal were to traffic an emu as part of a money laundering scheme. Gambling and its regulatory blind spotsĪustralia’s financial crime law and policy, in many areas, is nauseatingly comprehensive. This article examines the attempts – both past and present – to amend the AML/CTF Act and Rules in relation to the provision of gambling services against the inherent challenge posed by the industry. News of Barangaroo Crown Casino’s alleged non-compliance with AML/CTF laws late last year raises the perennial question of how to best regulate the gambling industry.