Money Laundering

• Document No.

• AML/CTF Checklist

• Client / Site

• Conducted on

  Date

• Prepared by

• Personnel

New employees

• Do you verify the identity of a prospective employee

  Yes

  No

  N/A

• Do you do Personal Reference checks on prospective employees?

  Yes

  No

  N/A

• Do you do a Credit Reference check on prospective employees?

  Yes

  No

  N/A

• Do you do a Criminal Record check on a prospective employ

  Yes

  No

  N/A

Current Employees

• Do you checks on an employee promoted to a position with increase exposure to possible Money Laundering

  Yes

  No

  N/A

Employee Supervision

• Do you supervise employees to ensure the follow AML/CTF procedures

  Yes

  No

  N/A

Employee Breaches

• Would an employee be disciplined, if they breached any AML/CTF procedure.

  Yes

  No

  N/A

Employee Training

• Do you train your employees in AML/CTF procedure

  Yes

  No

  N/A

• Are all employees trained AML/CTF Procedures.

  Yes

  No

  N/A

• How often do employees receive AML/CTF training

  Yes

  No

  N/A

• Choose from the following options.

  Select EBET Gaming Maxgaming DMS TAB reports Staff Interaction

  • EBET Gaming
  • Maxgaming DMS
  • TAB reports
  • Staff Interaction

• Is the training delivered by the AML/CTF Officer?

  Yes

  No

  N/A

• How is the training delivered?

  Yes

  No

  N/A

• Choose from the following options

  Clarify Customers information

  Further analysis of Information

  Analyse gaming history

  Submit a suspicious matter report

• Are records of employee training kept.

  Yes

  No

  N/A

• Are the employees tested on their understanding of AML/CTF after training is completed?

  Yes

  No

  N/A

• Do you ensure employees are kept up to date on new AML/CTF issues?

  Yes

  No

  N/A

• No action is taken against employees when they breach any AML/CTF procedures?

  Yes

  No

  N/A

Responding to Austrac Feedback

• Is the AML/CTF officer responsible for responding to AUSTRAC?

  Yes

  No

  N/A

• The AML/CTF Officer does not have to relay AUSTRAC feedback to relevant employees?

  Yes

  No

  N/A

• What timeframe have you set for responding to AUSTRAC feedback

  Yes

  No

  N/A

• Choose from the following options

  Duty Manager

  Gaming Manager

  CEO

  Supervisor

Independent Review process

• Independent review must not of been part of the design of the AML/CTF program, correct?

  Yes

  No

  N/A

• Is there currently and Independent Reviewer nominated?

  Yes

  No

  N/A

• If an Independent Reviewer is nominated, how often will a review be conducted?

  Yes

  No

  N/A

• Choose from the following options

  Every 12 Months

  Every 24 Months

• How will the Independent Reviewer convey recommendations arising from the review?

  Yes

  No

  N/A

Customer Due Dilligence

• When do you update, verifying and re-verifying customer information

  Yes

  No

  N/A

• Choose from the following options

  Membership Renewals

  Change of Address Notification

• How do you monitor your customers gaming transactions?

  Yes

  No

  N/A

• Choose from the following options

  EBET Gaming

  Maxgaming DMS

  TAB reports

  Staff Interaction

• When do you review your transaction records?

  Yes

  No

  N/A

• Choose from the following options

  Clarify Customers information

  Further analysis of Information

  Analyse gaming history

  Submit a suspicious matter report

• Who conducts the transaction monitoring for your business?

  Yes

  No

  N/A

• Choose from the following options

  Select Duty Manager Gaming Manager CEO Supervisor

  • Duty Manager
  • Gaming Manager
  • CEO
  • Supervisor

• If suspicion arises in regard to AML/CTF procedures, what must do one or more of the following

  Yes

  No

  N/A

• Choose from the following options.

  Select Clarify Customers information Further analysis of Information Analyse gaming history Submit a suspicious matter report

  • Clarify Customers information
  • Further analysis of Information
  • Analyse gaming history
  • Submit a suspicious matter report

• Who in your venue is responsible for conducting enhanced customer due dilligence

  Yes

  No

  N/A

• Choose from the following options

  Select Duty Manager Gaming Manager CEO Supervisor

  • Duty Manager
  • Gaming Manager
  • CEO
  • Supervisor

Documenting and reporting

Customer information

• Do you review your customers KYC information.

  Yes

  No

  N/A

• Once a year for all Members and whenever Members change their details, for example move house.

Declaration

• Select date

  Date

• Add signature

  Sign