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Customer Due Diligence and Reverification: Why they’re critical for Australia’s Wagering sector

Customer Due Diligence and Reverification: Why they’re critical for Australia’s Wagering sector

The regulatory environment for Australia’s wagering and gaming sector is entering a new phase. With the Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Amendment Act 2024 now in effect and key reforms commencing from 31 March 2026, AUSTRAC has made it clear that customer due diligence (CDD) and reverification are no longer procedural checkboxes, they are central to an outcomes-based, risk-driven compliance model.

For wagering operators these expectations build on the stricter pre-verification requirements introduced in September 2024, mandating verification before account creation to minimise vulnerabilities at onboarding. Combined with the lowered CDD threshold from $10,000 to $5,000, the message from AUSTRAC is unmistakable: early and ongoing verification is essential to protecting the integrity of the sector.

Recent reforms under the AML/CTF Amendment Act 2024 and AUSTRAC’s 2025 AML/CTF Rules have raised the bar for compliance:

  • Risk-based AML/CTF programs
    AUSTRAC has shifted from prescriptive checklists to risk-based, outcomes-focused obligations. Operators must assess money laundering, terrorism financing, and proliferation financing risks, to tailor their approach to KYC based on risks.  
  • Enhanced CDD and EDD triggers
    The 2025 rules introduce stricter requirements for high-risk scenarios, including:
    • Politically Exposed Persons (PEPs) and their associates.
    • Large or complex transactions.
    • Cross-border dealings with high-risk jurisdictions: operators must verify source of funds and wealth, using documentary evidence and multiple independent identity sources.
  • Sanctions compliance embedded
    Operators must now integrate financial sanctions screening into AML/CTF programs, ensuring they can detect sanctioned individuals and pause or suspend accounts.
  • Data integrity and record-keeping
    Operators must retain sufficient verification evidence for seven years, documenting the verification process rather than merely storing copies of identity documents.

Reverification and ongoing due diligence

The shift towards ongoing CDD means operators must revisit and refresh customer information when risk factors change. For wagering operators, this could include:

  • A customer significantly increasing betting activity.
  • Moving from domestic wagering to international event participation.
  • Linking with payment methods or wallets raising AML/CTF risk indicators.
  • PEPs and or sanctions status change.

Reverification ensures that operators maintain current insights into customer behaviour and risk exposure, aligning with AUSTRAC’s guidance for dynamic, adaptive compliance frameworks.

What wagering operators should prioritise 

AUSTRAC’s 2025-26 expectations stress proactive preparation rather than reactive compliance. For wagering operators, that means acting now in several critical areas:

  • Update AML/CTF programs and risk assessments to reflect new thresholds, terminology, and ongoing monitoring requirements.
  • Review onboarding platforms to ensure real-time verification technology supports pre-account opening obligations and ensure customer onboarding workflows meet current/new requirements.
  • Align training and reporting frameworks so front-line staff and compliance teams understand when reverification must be triggered.  
  • Engage technology providers capable of implementing automated identity and behavioural monitoring, ensuring accuracy and auditability at scale.  

AUSTRAC has committed to supporting industry transitions through upcoming guidance and educational programs, but operators are expected to demonstrate early progress through implementation planning and documented risk management improvements.

Strengthening trust while meeting obligations

Complying with the evolving CDD and reverification requirements is more than a regulatory necessity; it is a commercial imperative. Strengthened identification processes not only reduce AML/CTF risk exposure but also reinforce safer gambling and community trust in Australia’s wagering sector.

As AML/CTF reforms come into full effect, wagering operators that embed proactive, technology-driven customer due diligence will lead in both compliance and credibility. This clearly demonstrates that effective risk management and responsible wagering can successfully coexisting within a regulated and transparent market.

Connect with our team of experts to discuss your organisation's customer due diligence and reverification requirements.