Newly appointed Entain Australia interim CEO Andrew Vouris is wasting no time making a statement.
“I want us to win, yes, but not at all costs,” he said recently. It’s a line that marks a conscious shift in tone and ambition. A step away from legacy cultures that flirted with legal minimalism, toward a future that embraces ethical leadership, transparency and sustained trust.
This is not just PR. It echoes a broader repositioning we’ve seen before, most notably Crown Resorts, post Royal Commissions. Once fueled by compliance equivocation and conflicted incentives, Crown’s transformation is now pinned to culture, accountability and leadership. Entain, facing live Federal Court proceedings from AUSTRAC, appears to be charting a similar path.
Let’s be clear. AUSTRAC’s case against Entain is serious.
The agency alleges systemic non-compliance with AML/CTF laws: poor oversight, tokenistic customer due diligence and the use of pseudonyms to shield high-risk customers. The picture painted is of a company vulnerable to criminal exploitation, lacking controls over third party cash deposits and failing to understand or manage its risks.
Yet what’s equally important is how Entain is responding. Vouris’ early signals – prioritizing integrity, recalibrating ambition and redefining what “winning” means – matter. Not only for Entain’s future, but for what they signal to the rest of the sector: that ethical leadership is not a constraint, it’s a competitive advantage.
Clubs should be paying attention
Too many clubs, by contrast, are mired in boilerplate AML/CTF programs, a history of outsourced advice accepted without scrutiny, and board reports taken as read. What might have once passed as efficient delegation now looks increasingly like complacency.
The AUSTRAC case against Mounties has made that reality uncomfortably clear.
AUSTRAC’s 2024 National Risk Assessment designates pubs and clubs as “medium risk” for money laundering. But when you account for high volumes of cash, outdated controls and fragmented governance, many clubs in practice may fall into riskier terrain.
Let’s also be fair. Many clubs are structurally unique. They serve a social or community purpose, often governed by volunteer directors, and lack the governance depth of listed entities. But size and structure don’t absolve responsibility. A club with tens of millions in gaming revenue is running a serious commercial enterprise and needs to meet a serious regulatory standard.
AUSTRAC could not have been clearer: function can be delegated, but obligation cannot. Directors and executive teams are responsible. You can’t buy compliance off the shelf, slap your logo on it and expect it to hold under scrutiny.
Yet that’s exactly what’s happened in too many cases – generic policies, misunderstood risk assessments and third party consultants setting the tone rather than in-house capability asking tough questions. Compliance, not seen as core to the business, got relegated to the back office.
From passive compliance to proactive governance
The risk is no longer just theoretical. It’s financial, reputational and in some cases, criminal.
Boards must shift their thinking. AML isn’t about ticking boxes. It’s about protecting your venue, your members and the sector. It’s about understanding who your customers are, how they interact with your business and whether criminal elements are exploiting gaps in your systems.
The sector must purposefully pivot from passive compliance to proactive risk management:
- Build programs that reflect your specific risk profile, not someone else’s ill-fitting template
- Build and scale a compliance function fit for your organization
- Leverage RegTech to bolster capability and outcomes, and support accountability at the executive and board level
- Treat AUSTRAC guidance not as suggestions, but as minimum expectations
Entain’s posture shows reform is not only possible, but powerful. It shows that leadership can respond to scrutiny not with deflection or delay, but with a renewed sense of purpose and responsibility.
AUSTRAC’s litigation against Mounties ought to be understood as a warning and a call to action. One of the largest and most profitable club groups in the country, with over 1,400 gaming machines and hundreds of millions in annual revenue, now finds itself in the Federal Court facing allegations of serious and systemic AML/CTF breaches. AUSTRAC alleges Mounties failed to adopt and maintain a compliant AML/CTF program, exposing its venues to exploitation by criminal actors. In short: high revenue, high visibility and inadequate controls – a combustible mix that caught the regulator’s attention.
The lessons are not abstract. Mounties’ governance structures, risk culture and operational blind spots are not unique. Many clubs operate under similar conditions – community focused, volunteer governed and commercially significant. But those same conditions can no longer be used to excuse vulnerability to financial crime. As AUSTRAC has made clear, enforcement action is not reserved for casinos or sports betting operators – it now squarely includes the club sector.
Waiting for a knock on the door is not a strategy. It’s paralysis.
Now is the time to step forward, not step back. Boards must engage, executives must lead and compliance must be seen for what it truly is: not a cost centre, but a critical shield – for reputation, for members and for the future viability of the industry.
Now is the moment for industry leaders, especially in clubs and hotels, to step up, engage and help drive a sector wide reset. We need more voices leaning in, more organizational exemplars and more boards treating AML as a central governance priority, not a compliance footnote.
The AML/CTF Act has been in force since late 2006, with obligations phased in and a policy principles period allowing time for adjustment. Nearly two decades on, those core obligations remain, but regulatory expectations have matured, visibility has sharpened and tolerance for complacency has exhausted.
