The ACMA has a range of enforcement tools available to it which include directing internet service providers to block sites which are deemed to be operating in breach of the Interactive Gambling Act. Separately, SkyCity Group (SA) was ordered by the Federal Court to pay a $67 million penalty in June 2024, after AUSTRAC launched civil penalty proceedings against it for breaches of the AML/CTF legislation. The Star’s Sydney, NSW casino licence has been suspended and a manager has been appointed to oversee operations while the suspension is in force and reforms to achieve suitability can be assessed. This has included action taken by AUSTRAC in relation to casino licensees in Vic, NSW, Qld, WA and also SA examining money laundering issues (including those concerning ‘junket operators’). The ACMA has also been particularly active in relation to enforcement action in connection with spam legislation where infringements by a number of wagering operators have been identified. Enforcement action by the ACMA is also likely to continue following the implementation of various legislative changes, including in relation to illegal gambling sites and following the recent commencement of the NSER.

Bingo is often regarded as minor gaming and may be conducted for fundraising or charitable purposes, typically by a community or other not-for-profit organisation. Corporate Bookmakers typically also offer ‘totalisator-derivative’ or ‘tote odds’ type betting. Corporate Bookmakers offer fixed-odds betting online and over the telephone on sport, racing and other approved events, whereas On-course Bookmakers offer fixed-odds betting on-course and, subject to approval, also over the telephone and in some instances online on similar events as a Corporate Bookmaker. Corporate Bookmakers are commonly licensed in the NT, whereas On-course Bookmakers (which may have online operations) are licensed in the relevant state or territory. There are also various subordinate legislative instruments, including regulations, which have not been included. There are many pieces of legislation that are incidental to gambling activity (for example, legislation setting the applicable gambling tax rates). For completeness, the authors note that the list of gambling- related legislation below is not an exhaustive list.

In a land-based context, the Victorian regulator has been particularly active in targeting underage gambling in pubs and clubs in particular – a practice that is illegal in all Australian jurisdictions. At a federal level and in relation to anti-money laundering and counter-terrorism financing compliance, a large Australian gambling company paid a civil penalty of AUS $45 million to AUSTRAC in relation to admitted breaches of the AML/CTF Act. At the time of writing, casino licensees in NSW and Qld have been deemed unsuitable to hold the licences issued in those jurisdictions. AUSTRAC has also recently commenced the first prosecution of a prominent licensed club group for alleged breaches of the AML/CTF Act related to its operation of gaming machines. The use of digital currencies (including cryptocurrency) for gambling purposes is not common in the jurisdiction and, in the case of online wagering and betting, was expressly prohibited following amendments to the Interactive Gambling Act in 2024. In addition, a number of Corporate Bookmakers have recently been required by AUSTRAC to appoint independent auditors to assess their AML/CTF compliance, with one subsequently entering into an enforceable undertaking with AUSTRAC.

Compliance Reporting Deadline — Q1 2026

The authority exercises enforcement powers including licence suspension and revocation. The authority maintains a public register of licensed entities and publishes enforcement actions as required. All licensed operators are subject to defined regulatory standards, ongoing compliance obligations, and supervisory oversight. The authority is responsible for the issuance, supervision, and enforcement of Internet Gaming Licences within its lmct+ games jurisdiction. The designated regulatory authority for the licensing and supervision of internet gaming operations under the laws of the Autonomous Island of Anjouan. The firm ensures compliance with federal and state regulations by assisting clients in obtaining advertising approvals and reviewing content for compliance with advertising laws. In addition to licensing, Senet advises clients on company formation and incorporation, corporate structuring, and specialised due diligence, particularly for investors, banks and financial sponsors.

This is a departure from the previous ‘point of supply’ regime, under which states and territories derived no betting tax revenue from Corporate Bookmakers and other licensed betting operators taking bets online in the relevant jurisdiction. The state and/or territory taxes that apply to gambling products depend upon the relevant licence under which the product is being offered, the type of product and also the jurisdiction in which the product is offered. Separately, the CCA imposes penalties for, amongst other things, misleading and deceptive conduct (including through advertising). On-course Bookmakers offer substantially the same fixed-odds betting on-course and, subject to approval, also over the telephone and in some instances online. With the exception of virtual/simulated racing (which is generally only offered in retail venues including hotels and clubs), this betting is generally offered at racecourses, retail venues, online and by telephone. The Victorian regulator subsequently announced in March 2024 that it was satisfied that Crown Melbourne was suitable to operate the casino and that it was in the public interest for the casino licence to remain in force. An application for a Corporate Bookmaker Licence issued in the NT, or an application for an On-course Bookmaker Licence, typically takes between three and six months for approval and can be made at any time. The number of licences available are limited and there are typically only one per state and territory (except in the case of current casino licences held in each of Qld, NT and NSW, the two recently issued Vic keno licences, and potentially for new wagering licences) and the processes are very infrequent.

The authority's regulatory scope encompasses all internet gaming activities conducted under licences issued within the jurisdiction, including both B2C and B2B operations. The regulatory framework defines licensing standards, due diligence requirements, and compliance obligations applicable to all internet gaming operations within the jurisdiction. A state or territory licence is typically required to operate a bingo centre in the relevant jurisdiction. Casino table gaming and gaming machines, Retail Wagering, lotteries and keno all require an operator licence, which is typically long-dated and is granted by the relevant Australian state or territory. Using these powers, the federal government has enacted legislation regulating, amongst other things, interactive gambling, anti-money laundering and counter-terrorism financing (AML/CTF) and consumer and competition protections (also known as anti-trust matters in some other jurisdictions). The firm’s reputation is built on deep sector expertise, sound judgement, and a thorough understanding of the complex legal and regulatory frameworks that govern gambling across both jurisdictions. Senet's specialisation spans various sectors within the gambling industry, including waging operators, principal racing authorities, casinos, lotteries, licensed gaming venues, social gaming providers and manufacturers.

Revised Certificate Verification Framework

There is no single overarching statute regulating gambling activities in Australia, nor is there a single overarching gambling authority. If games are not entirely skill-based (that is, there is an element of chance), then they will be subject to the relevant gaming laws. The ACMA has commented that social casinos are an example of the ongoing convergence of gaming and gambling activities and should be monitored. Betting on fantasy sports in Australia is offered by some corporate bookmakers licensed in the NT (Corporate Bookmakers). In addition to casinos, poker is also played in hotels and clubs without generally being regulated in the same manner as a traditional casino table poker game, provided no third party (i.e. the venue owner/operator or tournament organiser) gains a percentage or share of any amount gambled. If a site relies on logos or vague wording without a traceable entry, assume it lacks the required authorisation. Many white-label sites operate under a platform provider’s licence.

This network provides the firm with insights that inform better regulatory, corporate and commercial outcomes tailored to its clients' needs and expectations. This breadth of experience gives Senet a unique commercial and regulatory perspective, and a clear understanding of the pressures faced by its clients. Known for his calm approach, attention to detail and strength in legal research, he brings a forward-thinking mindset to help clients respond to evolving regulatory challenges. Prior to joining Senet, Alexander was part of the Solicitors Assisting the Royal Commission into the Management of Police Informants (Lawyer X), where he worked under intense pressure on a range of intricate legal and procedural issues. His strategic insight and depth of legal knowledge contribute to delivering clear, effective solutions to clients operating in highly regulated environments. At Tabcorp, she served as Deputy General Counsel – Wagering and Media, advising on major strategic initiatives including the integration of two ASX-listed entities, regulatory investigations and responsible gambling programs. The authors also anticipate reforms in the area of ‘trade promotion lotteries’ which are a form of free-entry permissible lottery conducted for the purpose of promoting a business or trade.