Australian club compliance,
in plain English.

The venue must maintain a current register of self-excluded persons and ensure staff can access it to check patrons on entry or when problem-gambling behaviour is observed.

The venue must not permit a self-excluded person to enter the gaming area. If a self-excluded patron is identified, entry must be refused and the refusal recorded.

A self-excluded patron may only have their self-exclusion lifted after the minimum period and following the prescribed revocation process.

Staff observing indicators of problem gambling must offer the patron information about self-exclusion and, where requested, facilitate it.

A trained Responsible Gambling Officer must be on duty whenever gaming machines are operating. The shift must be logged so the venue can prove RGO presence on demand.

Venues must observe patrons for signs of gambling harm and intervene where necessary — including welfare checks, breaks in play, and referral to support services.

The prescribed problem-gambling warning, self-exclusion information, and counselling contact signage must be displayed at entries to the gaming area.

Incident records must be retained for the prescribed period (typically three years) and produced on request to L&GNSW inspectors.

Records of refused entries (including self-exclusion breaches) must be retained and made available to L&GNSW on inspection.

Routine inspections and tamper checks of gaming machines must be logged with date, time, machine ID, and inspector.

Certain serious incidents (e.g. assault in the gaming area, police intervention) must be notified to L&GNSW within the prescribed timeframe.

The venue compliance register must be reviewed monthly with findings and any corrective actions recorded.

Review the EGM shutdown log monthly to confirm all mandatory close periods, regulator-directed shutdowns, and fault closures were correctly recorded and actioned.

A registered club must not operate more EGMs than authorised by its gaming machine entitlement. In NSW the statutory cap for registered clubs is 450 EGMs.

NSW registered clubs must maintain an approved GPOM that documents gaming policies, staff responsibilities, harm-minimisation procedures, and incident handling.

NSW venues must make patrons aware of voluntary pre-commitment options. Participation is voluntary.

A hotelier or registered club must ensure each approved gaming machine on its premises is not operated for the purposes of gambling between 4 am and 10 am on each day of the week (the "general 6-hour shutdown period"), subject to any approved 3-hour weekend variation (s.40), hardship dispensation (s.40A), or early-opener provision (s.41).

All electronic gaming machines installed on or after 1 July 2023, and all approvals issued (except bug fixes), must implement a $500 cash-input limit (BKNTLIM = NSW $500). When the credit balance reaches $500, the machine must stop accepting tickets, coins, notes and CCCE transfers. The cap is not retrospective — pre-1-July-2023 machines remain at the historic $5,000 limit. The Star Sydney casino is not subject to this circular.

As of 5 May 2026, NSW gaming machines may accept any banknote denomination approved by the Authority for use in the machine (GMA s.80(3)(b)). There is no statutory, regulatory, or technical-standards prohibition on a gaming machine accepting $50 or $100 notes specifically. The cash-input control mechanism is the BKNTLIM credit-balance cap (see gma-nsw-cash-input-cap-new-machines), not a per-denomination prohibition. The original calibration pack's "s.47C $50/$100 prohibition" claim was unsourced; s.47C governs ATM/EFTPOS facilities, not note acceptors.

A hotelier or registered club must not permit a cash dispensing facility to be visible from an approved gaming machine, or from within / from an entrance to or exit from a gaming area in the hotel or registered club.

A hotelier or registered club must not permit (a) an approved gaming machine or part of one, (b) a monitor used to display the jackpot prize from an authorised progressive system, or (c) an entrance to or exit from a gaming area, to be visible from a cash dispensing facility.

A cash dispensing facility must be located outside a 5-metre radius of any entrance to or exit from a gaming area in the hotel or registered club, unless the Secretary has granted an approval under cl.28(6) — only available where compliance is impossible due to EPA Act 1979 / WHS Act 2011 contraventions, and only for the furthest possible accessible location.

A hotelier or registered club must not permit signage advertising or giving directions to a cash dispensing facility that is visible from (a) an approved gaming machine, or (b) any part of a gaming area in the hotel or registered club.

A hotelier or registered club must not permit signage or advertising about gaming machines that is (a) located on or part of a cash dispensing facility (including a digital display), or (b) visible from a cash dispensing facility. cl.28B(2): does not apply if the signage/advertising is a notice for the purposes of, and in accordance with, cl.24.

The venue must keep a gambling incident register in a form approved by the Secretary and record information about reportable gambling incidents in accordance with Division 4 of Part 4 of the Regulation. cl.50K(3) defines four categories: (a) a patron displaying behaviour indicating they are experiencing or at risk of experiencing gambling harm; (b) a patron, or a person identifying as a family member, asking for information about a self-exclusion scheme or intervention; (c) a breach or attempted breach of a self-exclusion scheme; (d) an offence, alleged offence, or incident involving a minor.

A reportable gambling incident must be recorded in the gambling incident register as soon as practicable but no later than 24 hours after the incident occurs (cl.50K(3) opening words). Details of action taken in response to the incident must also be recorded as soon as practicable but no later than 24 hours after the incident occurs (cl.50K(4)). The 24-hour clock is calendar hours, not business hours — the regulation uses "24 hours" without qualification.

The venue must have a written AML/CTF programme document covering risk assessment, governance, training, independent review, and transaction reporting obligations. The programme must be kept current.

The venue must conduct and document a money-laundering / terrorism-financing risk assessment covering customer types, designated services, delivery channels, and jurisdictions. The assessment must be revisited when circumstances change.

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, with a written evaluation report delivered to the governing body and the senior manager responsible under s.26P.

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

Before providing a designated service above the threshold, the venue must identify the customer and verify their identity using reliable and independent documentation.

The venue must conduct ongoing due diligence on customers, monitor transactions for consistency with the customer profile, and update the CDD information when triggers occur.

Where a customer or transaction presents higher ML/TF risk (e.g. PEP, high value, unusual pattern) the venue must apply enhanced due diligence measures.

Cash transactions of $10,000 or more (or the foreign currency equivalent) must be reported to AUSTRAC within 10 business days.

Where the venue forms a suspicion on reasonable grounds about a customer, transaction, or attempted transaction, it must lodge a Suspicious Matter Report with AUSTRAC within the prescribed timeframe (24 hours for terrorism financing, 3 business days otherwise).

Records relating to designated services, CDD, transactions, and the AML/CTF programme must be retained for seven years.

The venue must enrol with AUSTRAC and keep its enrolment details current. Changes to beneficial ownership, key personnel, or contact details must be notified within the prescribed timeframe.

The appointed AML/CTF compliance officer must be notified to AUSTRAC and changes to that appointment notified within the prescribed timeframe.

Reporting entities must lodge an annual compliance report with AUSTRAC covering programme effectiveness and reportable transactions.

The venue must conduct appropriate due diligence on any person it employs or engages to perform AML/CTF functions (screening, ongoing monitoring) — covering employees, contractors, agents and outsourced providers, per AUSTRAC's post-reform "personnel" framing.

It is an offence to disclose information about an SMR (or that an SMR is required), or about a s.49(1) or s.49B(2) notice, to any person other than an AUSTRAC entrusted person, where the disclosure could reasonably be expected to prejudice an investigation. Two statutory exceptions: (1) s.123(4) crime-prevention disclosure by legal practitioners, accountants, or persons specified in the Rules — defendant bears evidential burden; (2) s.123(5) information-sharing among reporting entities for ML/TF/proliferation-financing/serious-crime detection, deterrence, or disruption — subject to conditions in regulations.

A senior member of a qualifying agency may issue a Form 1 keep-open notice requiring the venue to continue providing a designated service to a specified customer in support of a serious-offence investigation (≥2 years imprisonment). When a keep-open notice is in force, the venue is exempt from s.26G/s.28/s.30 obligations to the extent compliance would alert the customer to the investigation. The platform records the Form 1, the expiry date, and any Form 3 extensions, and suspends default CDD/EDD treatment for the affected customer for the duration.

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.

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.

The venue must have a clearly expressed and up-to-date privacy policy describing how personal information is collected, used, stored, disclosed, and how individuals can access or correct it.

Personal information must only be collected where reasonably necessary for the venue's functions and by lawful and fair means.

At or before the time of collection, the venue must take reasonable steps to notify the individual about the collection, its purposes, and their rights.

Personal information collected for one purpose may only be used or disclosed for a secondary purpose in specified circumstances (consent, related purpose, law enforcement, etc.).

The venue must take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure.

When personal information is no longer needed for a permitted purpose, the venue must take reasonable steps to destroy or de-identify it — subject to any legal retention obligations (e.g. AML/CTF 7-year retention).

An individual has a right to request access to the personal information the venue holds about them, and the venue must respond within the prescribed timeframe.

The venue must take reasonable steps to correct personal information on request where it is inaccurate, out of date, incomplete, irrelevant, or misleading.

Participating venues must register and maintain active credentials with the MVSE scheme operator and access the shared self-exclusion register.

When a self-excluded person attempts to enter a participating venue, the venue must log the breach in the MVSE portal so other venues are notified.

Participating venues must treat self-exclusions logged in the MVSE register as equivalent to their own self-exclusions and refuse entry accordingly.

If the sale or supply of liquor after midnight on the licensed premises is authorised at least once a week on a regular basis, it is a condition of the licence that the licensee maintains an incident register in the form approved by the Secretary. The register must record violence/anti-social behaviour, immediate-vicinity incidents, s.77 turn-outs, and any prescribed kinds. Inspection rights and 3-year retention also live at s.72L. Many community/registered clubs without late-trade authorisation do NOT have an automatic s.72L obligation.

A licensee, manager, employee or agent must not supply liquor to a person who is intoxicated on the licensed premises. Staff are trained in Responsible Service of Alcohol (RSA) under the existing lgnsw-codes RSA cert obligation; refusal-of-service judgement is the floor staff member's in-the-moment call.

The Secretary may declare a precinct or area to be subject to a late-hour entry restriction (s.87). When in force, no patron may enter the premises after the declared time except in accordance with the declaration (s.88). Provisions for making, varying, and revoking declarations are at ss.89–90. Declaration scope and conditions vary; the venue must consult any current declaration affecting its area.

The Authority (or in some circumstances a senior police officer) may make a short-term closure order (s.82) or, after a hearing, a long-term closure order (s.84) requiring the licensed premises to cease trading for a specified period. Failing to comply is an offence under s.82(6) or s.84(7) and is a category 1 demerit offence under the s.4 definition.

Registered clubs must hold an AGM each year within the timeframe set by the Act and the club's constitution, with proper notice to members. The AGM is where members receive the annual financial report and elect directors.

Director elections must follow the process set out in the club's constitution and the Act. Candidate eligibility (not disqualified under s.30A) and voter eligibility must be verified.

A person must not sit as a director if they are bankrupt, disqualified by ILGA, or otherwise ineligible under s.30A. The secretary must confirm eligibility on appointment and at least annually.

The club must keep a current register of all members with the particulars required by the Act. The register must be available for inspection by members and regulators per the Act's requirements.

Transactions between the club and a director (or an entity a director controls or benefits from) must be declared on the COI register, approved per the constitution, and disclosed to ILGA where required. Unresolved conflicts must not participate in the decision.

Directors, the secretary, and KMPs must declare any conflicts of interest on appointment and have them reviewed at least annually. The register records financial interests, related-party relationships, and personal relationships that could influence decisions. The venue runs and stores its COI register itself; Venue Axis does not host it.

Specific events — change of secretary, constitutional amendments, amalgamations, insolvency-triggering events — must be notified to ILGA within the prescribed timeframe.

Amendments to the club's rules or constitution require a members' resolution (special or ordinary depending on the rule) and — where the Act requires — ILGA approval. Records of the resolution and approval must be retained.

The club must prepare an annual financial report, have it audited where required by the Act, present it at the AGM, and retain it for inspection. This is the members' primary line of sight into club finances.

A member may request a copy of the current constitution; the club must provide it (often for a prescribed fee). The version held must be the current consolidated version including all registered amendments.

A registered club must continue to pursue the objects and core activities recorded in its constitution. Material drift from those objects can trigger ILGA review of the club's registration.

Amalgamating with another club or winding up operations are major structural decisions with specific statutory steps — member resolutions, ILGA approval, asset disposition rules. The board must follow the Act's process precisely.

Each member of the governing body of a registered club that is not a "small club" must, within 12 months after becoming a member of the governing body, become a fully trained member by completing the prescribed ClubsNSW courses or NVR-RTO units of competency. Cl.21 defines "small club" as a registered club for which annual profit from gaming machines does not exceed $1 million; clubs above that threshold fall under cl.22.

For a small club (gaming-machine profit ≤ $1M annually), the governing body must include at least 2 fully trained members at all times. If the number of fully trained members falls below 2, the governing body must ensure that within the following 12 months the number is restored to 2 or more by appointing fully trained members or having existing members become fully trained.

The secretary or manager of a registered club must, within 2 years after becoming the secretary or manager, complete the course "Board Governance, the Company Secretary and the General Manager" conducted by or for The Club Managers Association of Australia. The duty does not apply to a person who is also a member of the governing body (typically because cl.22 or cl.23 already covers them).

A person is not required to complete training under cll.22–24 if the person has qualifications, skills, or work experience specified by the Secretary in guidelines published on the Department's website. The platform exposes the link to the Secretary's published exemption guidelines so the GM can match a director's prior qualifications against the exemption list before triggering the 12-month or 2-year clock.

Every person employed in a gaming area must hold a current Responsible Conduct of Gambling (RCG) certificate issued by an L&GNSW-approved provider. Certificates require renewal; the venue's training policy sets the renewal interval.

Gaming managers and designated duty managers are expected to hold the Advanced RCG qualification in addition to the standard RCG. The Advanced RCG covers detailed responsible gambling obligations and harm minimisation practices.

Under the Liquor Act 2007 (NSW), any person who sells, supplies, or serves alcohol must hold a current Responsible Service of Alcohol (RSA) certificate. The statutory renewal period is three years, though many venues require annual refreshers.

NSW venues must display prescribed responsible gambling information (including problem gambling helpline details and responsible gambling brochures) in the gaming area. L&GNSW periodically updates approved display materials.

Victorian venues with more than 20 EGMs must integrate with the YourPlay pre-commitment system. YourPlay allows patrons to set pre-commitment limits on time and money. Mandatory phase-in milestone: October 2028 for remaining venue classes.

In Victoria, the maximum number of EGMs per gaming venue is 250. This is lower than the NSW cap of 450.

Victorian venues must comply with the Responsible Gambling Code of Conduct, maintain a written Responsible Gambling Policy, train staff, and display required materials.

In South Australia, licensed premises other than the Casino are capped at 40 EGMs. This is significantly lower than NSW (450) and VIC (250).

SA venues must comply with the Responsible Gambling Codes of Practice, maintain a written policy, train staff, and display required materials. No direct equivalent to NSW GPOM.