Case Study: Raising the Standard for Financial Crime Compliance in Australia’s Pubs and Clubs
Summary
Australia’s pubs and clubs sector is operating in an environment of heightened regulatory scrutiny and evolving Anti Money Laundering and Counter Terrorism Financing (AML/CTF) obligations. Expectations from regulators, boards and communities have shifted from procedural compliance to demonstrable, enterprise-wide risk management capability.
Castle Hill RSL Group (CHRG), one of Australia’s premier hospitality and entertainment groups, recognised early that meeting this new standard would require more than incremental system improvements. It would demand an integrated, forward-looking compliance ecosystem capable of supporting regulatory intent, operational complexity and future reform.
Through its partnership with Cherryhub and BNDRY, CHRG has modernised its financial crime compliance framework, consolidating fragmented processes into a unified, data-driven platform. The result is not simply improved efficiency, but a scalable model of best practice for clubs navigating an increasingly complex compliance landscape.
The Challenge: A Sector Under Increasing Scrutiny
Across Australia, the gambling and hospitality sector faces intensifying oversight and regulatory reform. AML/CTF obligations continue to evolve, requiring operators to demonstrate robust risk assessment, effective monitoring and clear auditability across large and complex patron environments.
Like many major hospitality groups, CHRG operates in a high-volume, multi-venue environment involving hundreds of gaming machines, tens of thousands of customers and intersecting regulatory obligations. While the Group had established compliance processes in place, the broader industry shift toward integrated, technology-enabled oversight prompted a strategic reassessment to streamline existing procedures.
Key considerations included:
- Enterprise Visibility
Customer risk data, transaction monitoring and enhanced due diligence records existed across multiple systems; while functional, the structure limited the ability to achieve a consolidated, real-time view of risk across the Group.
- Operational Efficiency
Compliance resources were heavily focused on manual data collation and reconciliation rather than proactive risk analysis and decision-making. - Regulatory Agility
With ongoing legislative refinement and regulatory expectations evolving, the Group required a framework capable of adapting quickly without recurring structural redesign.
The Group was not seeking software alone. It sought a partner with deep regulatory understanding and the ability to help architect a modern compliance model aligned with both operational realities and regulatory intent.
The Solution: Building an Integrated Compliance Ecosystem
CHRG selected Cherryhub and BNDRY to support the centralisation and modernisation of its financial crime compliance program.
BNDRY implemented a unified platform designed to aggregate compliance data, streamline workflows and support a live, risk-based approach to monitoring.
Key capabilities deployed included:
- Unified Case Management: Transaction alerts, incident reports and patron interactions were consolidated into a single, auditable timeline, enabling clearer visibility and more consistent decision-making.
- Dynamic Risk Scoring: The Group transitioned from static risk registers to a live patron risk model that updates in real time based on behavioural indicators and monitoring outcomes.
- Process Automation: Routine checks, reporting triggers and workflow steps were automated where appropriate, allowing compliance professionals to focus on complex assessment rather than administrative tasks.
"We did not want a digital filing cabinet. We wanted a system that helped us approach risk with greater clarity and confidence. BNDRY provided the architecture to support that shift." – Andrew Kelly, Head of Risk, Castle Hill RSL Group
The BNDRY Difference: Strategic Partnership
While the platform delivered structural improvements, CHRG attributes much of the project’s success to the partnership approach adopted by Cherryhub and BNDRY.
1. Agile and Responsive Collaboration
Rather than imposing a fixed product model, BNDRY worked closely with the Group to refine workflows in line with operational realities. Adjustments were made iteratively, ensuring the system aligned with the pace and complexity of a large club environment.
2. Deep Regulatory Expertise
BNDRY’s team demonstrated strong working knowledge of the AML/CTF legislative framework. This ensured that system design reflected regulatory intent, not merely technical functionality. The partnership extended beyond configuration to strategic dialogue about compliance maturity and risk governance.
3. User-Centric Implementation
The implementation process prioritised usability for both frontline staff and compliance officers. Training and configuration were tailored to ensure that the system supported, rather than complicated, daily operations.
This collaborative approach ensured that technology enhanced internal capability rather than replacing it.
The Results: A Model for Modern Club Compliance
Since implementing the BNDRY platform, Castle Hill RSL Group has materially strengthened its financial crime compliance capability.
- Holistic Risk Oversight: The Group now operates with a consolidated, enterprise-wide view of compliance activity across venues and patron interactions.
- Improved Efficiency and Focus: Administrative time spent on manual reconciliation has reduced, allowing greater emphasis on proactive risk analysis and decision-making.
- Scalable and Future-Ready Architecture: The compliance framework is designed to evolve alongside regulatory reform, providing agility in an environment of ongoing legislative and policy change.
Most importantly, the project has positioned CHRG at the forefront of integrated compliance practice within the club sector. By investing in structured, technology-enabled risk governance, the Group has demonstrated how clubs can move beyond reactive compliance toward strategic, data-informed oversight.