Sectors
Licensed Gaming Venues, Clubs and Hotels
Licensed gaming venues in Australia, including hotels and clubs, must adhere to a range of legal and regulatory requirements.
Compliance with obligations not only ensures lawful operation but also enhances the commercial attractiveness of venues for potential buyers and investors.
To operate, venues are required to hold a gaming venue licence (issued by the relevant state or territory government or regulatory agency) and an entitlement, permit, or licence for each gaming machine. The only exception applies to casino operators, who are permitted to operate machines under their casino licence. Additionally, strict local government planning requirements often apply to gaming machines, and the number of machines a venue can operate is capped based on these permits or entitlements and legislation.
Appropriately managing anti-money laundering and counter-terrorism financing-related obligations and risks is critical for operational sustainability. The sector remains a focus area for the Australian Transaction Reports and Analysis Centre (AUSTRAC) and state and territory regulators. It is also essential for gaming venue operators to ensure that management and staff actively manage their obligations in respect to responsible service of gaming which is similarly a regulatory focus area.
Comprehensive legal and regulatory services for gaming venues
We help gaming venues, clubs and hotels remain compliant, protect against financial crime, and minimise gambling-related harm.
We advise venues across Australia in key areas, including:
Purchase and sale of gaming venues
AML/CTF transaction monitoring, policies and procedures
Gaming Plan of Management (NSW)
Responsible Gaming and Codes of Practice
Responsible gaming policies and strategies
Licence applications, variations, and renewals
Management of gaming machine entitlements
Outsourced service arrangements
Loyalty program compliance
Navigating regulatory approvals for new or varied product offerings
Representation at regulator hearings and tribunal proceedings
Club constitutions, elections and governance management
Anti-Money Laundering compliance for licensed gaming venues
We work closely with gaming venues to provide legal and advisory services and ensure compliance with Anti-Money Laundering / Counter Terrorism Financing laws and regulations including:
AML/CTF policy and procedure reviews
Access to Senet’s online ‘Compliance Vault’ providing tools, updates and checklists to assist with ongoing AML/CTF implementation
Using off-the-shelf AML/CTF programs or risk assessments can expose your venue to significant risks, and AUSTRAC has recently cautioned industry about the quality of generic programs.
Our program is tailored to your venue. We use a comprehensive risk assessment framework to evaluate the risks your business reasonably faces. We consider over 30 quantitative and qualitative variables to create an accurate risk profile and mitigation strategy for your business.
Our Compliance Vault serves as your venue’s central resource for AML/CTF compliance. Developed by industry experts, it simplifies the implementation process by providing everything you need in one place—your AML/CTF program, risk assessment, transaction monitoring, policies, procedures, templates, compliance registers, and annual declarations.
Our platform takes the complexity out of compliance, helping you stay on top of your legal obligations with ease.
Strategic advisors for the gaming industry
Senet’s team of industry experts has extensive experience advising regulators and operators in the gaming and gambling sectors. With strong industry insights and executive-level experience in the gambling sector, we provide advisory services to manage legal, regulatory and compliance risks effectively.
Our team is highly engaged with the casino and gaming industry, frequently speaking at leading gaming conferences and maintaining strong relationships with regulators and key stakeholders. This allows us to remain ahead of trends, understand key issues, and ensure our clients benefit from the latest industry developments.
Industry leadership and engagement
Senet proudly sponsored the International Association of Gaming Regulators (IAGR) conference in Melbourne in 2022, and our team members are active participants in the International Association of Gaming Advisors (IAGA), including in Washington DC in 2024.
Gambling Compliance Training
Through the Senet Compliance Academy, we offer comprehensive gambling compliance training, ensuring your staff remain compliant with Australia’s legal and regulatory standards. Our courses are designed to help businesses cultivate a compliance culture, protect against financial crime and reduce gambling-related harm.
Get in touch for a complete range of gambling law and advisory services
FAQ
Gaming Knowledge
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State and territory taxes on gaming machine revenue are complicated and vary significantly. By way of example, in Victoria, where average revenue per gaming machine is greater than $12,500 per month, the tax rate is 60.67%. Concessions apply for clubs.
There is also a Federal goods & services tax of 10% payable on net revenue from gambling products; however, State and Territory taxation rates sometimes take this into account, and it is offset against taxation payable to State and Territory governments.
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The introduction of cashless gaming has commenced in New South Wales and Victoria with the casino licensees deploying such technology for electronic gaming machines but it has not yet been deployed in hotels and clubs around the country. Focused trials of cashless gaming technology (or digital gaming wallet technology) have recently concluded in New South Wales and it is anticipated that its adoption will expand over coming months and years to the broader hotels and clubs environment.
In announcing the trial in 2021, the NSW government advised that it supports the fact that the digital proposal is linked to identity and a bank account, and that harm minimisation settings are involved. The technology will enable patrons to set spend and time limits for play, speak to a staff member, or even exclude themselves from the club, in addition to using their own mobile wallet to pay for a meal, membership and gaming services.
Issues related to money laundering and problem gambling were prominently exposed through an Inquiry in NSW, conducted under section 143 of the Casino Control Act 1992, and Royal Commissions into the casino operator and licence in Victoria and Western Australia, with cashless technologies seen as an important way of identifying and minimising these risks.
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Hotels and clubs must hold a venue operator’s licence and a permit/licence to operate each gaming machine within their licensed premises. There are often strict local government planning requirements that must be met in relation to gaming machines.
The number of gaming machines available in each state and territory is strictly regulated. In the case of a casino, it will depend upon the relevant casino licence. In the case of a non-casino gaming venue (hotel or club), whilst a venue operator’s licence is relatively straightforward and readily available (but can still take six to 12 months for approval of new entrants), the number of gaming machines which such venue may be permitted to operate is limited based on the ‘entitlement’ or permit/licence to operate those gaming machines. Various states (including NSW and Vic) have implemented harm minimisation measures to cap the number of gaming machine permits/licences on issue. Local government is also involved in the licensing process.
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Gaming in Australia is regulated primarily at a state and territory level although important federal law also applies in the areas of online gambling and anti-money launder and counter-terrorism financing in particular.
The Australian Communications and Media Authority (ACMA) regulates digital gaming in Australia at a federal level. Online casino gaming (including slot machines and poker) is prohibited in Australia under the Interactive Gambling Act 2001 (Cth) (Interactive Gambling Act).
Casino table gaming and gaming machines require an operator licence, which is typically long-dated and is granted by the relevant Australian state or territory.
Gaming machines are offered in casinos, hotels and clubs and are permitted under the various state and territory licensing regimes. In relation to hotels and clubs, a venue requires both a gaming venue licence and also a permit/licence for each gaming machine a venue operates. Gaming machines in WA can only be offered in the casino.
In Australia, gambling harm issues are often associated with gaming machines and the licence restrictions relating to the operation of gaming machines include more detailed responsible gambling obligations. Pre-commitment and other harm minimisation and consumer protection measures have been implemented in relation to gaming machines in Australia and moves are underway to introduce cashless gaming in various jurisdictions around the country. Cashless electronic gaming machine (EGM) operations have been introduced in casinos in New South Wales and Victoria and will follow in other jurisdictions for both casinos and licensed venues.
Gaming machine and other equipment manufacturers, software developers and technical services suppliers selling products and/or services used for gambling-related activities are also required to hold a relevant licence.
Poker can be conducted outside of a casino in hotels and clubs and played for money but is subject to restrictions in relation to issues such as how stakes are distributed, the charging of fees for participation and the involvement of dealers in the playing of the game. These requirements must be carefully navigated to avoid breaching the relevant legislation and regulation.
A person may also apply for an ‘internet gaming licence’ in the Northern Territory and offer their gaming products outside of Australia in certain circumstances.
The Australian Consumer and Competition Commission (ACCC) is responsible, under the Competition and Consumer Act 2010 (Cth) (CCA), for, amongst other things, enforcing Australian consumer protection laws. From a gambling perspective, the ACCC monitors compliance by gambling service providers of their obligations under the CCA, including gambling advertising (to ensure the consumer is not being treated unconscionably or unfairly, in breach of the CCA). It also takes appropriate enforcement action where it deems necessary.
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Gaming machines are offered in casinos, hotels and clubs and are permitted under the various state and territory licensing regimes. In relation to hotels and clubs, a venue requires both a gaming venue licence and also a permit/licence for each gaming machine (‘pokie’ or ‘slot machine’) a venue operates. Gaming machines in WA can only be offered in the casino. Casino operator licences typically include permission to operate gaming machines within the casino premises. However, the relatively new casino operator licence in NSW, issued for the Barangaroo casino which commenced operations in August 2022, does not include permission to operate gaming machines and the NSW government has granted exclusivity to operate gaming machines to the other major NSW casino licensee until 2041.
The number of gaming machines available in each state and territory is strictly regulated. In the case of a casino, it will depend upon the relevant casino licence. In the case of a non-casino gaming venue (hotel or club), whilst a venue operator’s licence is relatively straightforward and readily available (but can still take six to twelve months for approval of new entrants), the number of gaming machines that such venue may be permitted to operate is limited based on the ‘entitlement’ or permit/licence to operate those gaming machines. Various states (including NSW and Vic) have implemented harm minimisation measures to cap the number of gaming machine permits/licences on issue in certain lower socio-economic areas.
