1. Overview
The Star Sydney Casino operates as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and is enrolled with the Australian Transaction Reports and Analysis Centre (AUSTRAC). This document sets out the anti-money laundering, counter-terrorism financing and know your customer obligations that apply to all customers and to the operation of designated gambling services at The Star Sydney Casino.
The purpose of this policy is to explain what identity and verification requirements apply, when they apply, and what obligations both the venue and the customer carry under the applicable Australian regulatory framework.
2. Regulatory Framework
The Star Sydney Casino is subject to the AML/CTF Act and the AML/CTF Rules made under that Act. AUSTRAC is the primary regulator responsible for overseeing compliance with these obligations across the Australian gambling sector.
As a reporting entity, The Star Sydney Casino is required to:
- Maintain a documented AML/CTF programme
- Conduct customer identification and verification in accordance with the AML/CTF Rules
- Apply risk-based customer due diligence (CDD) measures
- Monitor customer activity on an ongoing basis
- Report suspicious matters and certain threshold transactions to AUSTRAC
- Retain records in accordance with prescribed timeframes
- Provide staff training on AML/CTF obligations
These requirements are not discretionary. They are legal obligations that apply regardless of the nature or frequency of a customer’s activity.
3. Customer Identification and Verification (KYC)
3.1 When Identification Is Required
The Star Sydney Casino is required to identify and verify a customer’s identity before providing designated gambling services or creating an account. This requirement applies at the point of onboarding. The venue must not provide a designated service until it is reasonably satisfied that the customer is who they claim to be.
This reflects the strengthened customer identification obligations that came into effect for gambling service providers from 29 September 2024 under AUSTRAC’s updated guidance. Under the current framework, verification must be completed prior to account creation or service commencement, not after.
3.2 Information and Documents Required
As part of the applicable customer identification procedure (ACIP), customers may be required to provide:
- Full legal name
- Date of birth
- Residential address
- A primary photographic identity document (such as a current Australian passport or driver licence)
- A secondary document confirming address or identity where required by the applicable risk assessment
The specific documents accepted and the combination required will depend on the customer’s risk profile and the nature of the service being accessed. The Star Sydney Casino reserves the right to request additional documentation where the initial information provided is insufficient to satisfy the identification requirement.
3.3 Verification of Information
Documents and information provided by customers are verified against reliable and independent sources. This may include electronic verification against government or third-party databases, document inspection, or a combination of both. Where electronic verification is used, the outcome is assessed against the standard of reasonable satisfaction required under the AML/CTF Rules.
4. Customer Due Diligence
4.1 Standard Due Diligence
All customers are subject to standard customer due diligence measures at onboarding. This includes collecting and verifying identity information and assessing the customer’s expected activity against their profile.
4.2 Enhanced Due Diligence
Enhanced due diligence measures apply where a customer or transaction presents a higher risk. Circumstances that may trigger enhanced measures include:
- Large or complex transactions
- Transactions involving jurisdictions identified as high-risk for money laundering or terrorism financing
- Customer activity that is inconsistent with the established profile
- Customers who are politically exposed persons (PEPs) or who have associations with PEPs
Where enhanced due diligence is required, The Star Sydney Casino may request additional information, apply additional monitoring, or restrict access to certain services until the review is complete.
4.3 Ongoing Monitoring and Re-Verification
Customer due diligence is not a one-time process. The Star Sydney Casino conducts ongoing monitoring of customer activity and transactions. Where monitoring identifies a change in risk profile, unusual activity, or information that is inconsistent with the customer’s verified identity, re-verification may be required. Customers will be notified if re-verification is needed and what information is required to complete it.
5. Transaction Reporting Obligations
The Star Sydney Casino is required to submit the following reports to AUSTRAC:
- Suspicious Matter Report (SMR): any transaction or activity that gives rise to a suspicion of money laundering, terrorism financing, or related offences
- Threshold Transaction Report (TTR): cash transactions at or above the applicable AML/CTF threshold in Australian dollars
Customers should be aware that these reporting obligations are mandatory and cannot be waived or overridden by customer request. The Star Sydney Casino is not required to notify a customer that a report has been submitted.
6. Impact on Account Access and Withdrawals
Where a customer has not completed the required identification and verification process, The Star Sydney Casino may:
- Decline to create an account or activate a service
- Restrict access to an existing account
- Place a hold on withdrawal requests until verification is completed
These measures are applied in accordance with the AML/CTF Act and are not discretionary. Customers who are subject to a verification hold will be advised of the documents or information required to resolve the matter.
7. Record Keeping
The Star Sydney Casino retains records relating to customer identification, verification, transactions and due diligence in accordance with the timeframes prescribed under the AML/CTF Act. These records are maintained securely and are available to AUSTRAC upon request. Customer data is handled in accordance with The Star Sydney Casino’s Privacy Policy and applicable Australian privacy legislation.
8. Customer Obligations
Customers are required to:
- Provide accurate and complete information when requested
- Supply identity documents that are genuine and current
- Notify The Star Sydney Casino of any material change to their identity information
- Cooperate with re-verification requests when required
Providing false, misleading or incomplete information in connection with an identity verification request may result in account suspension, termination of service and referral to relevant authorities.
9. Contact and Enquiries
Customers with questions about the identity verification process or this policy may contact The Star Sydney Casino through the official customer support channels listed on the venue’s website. Enquiries relating to a specific account or verification hold should be directed to the compliance or customer services team, with the relevant account details included.