BNDRY for Pubs and Clubs

If you run compliance at a pub, club, or RSL with gaming machines, your risk walks in off the street, plays in cash, and is often a member you see every week. This guide explains how BNDRY maps onto the compliance work a gaming venue actually does: how to set BNDRY up for a venue, and how the day-to-day processes — due diligence, investigations, information requests — play out on the gaming floor.

It assumes you already know your own AML/CTF program. Where a process has a standard shape in BNDRY, this guide points you to the tutorial that walks it step by step, and focuses instead on what's specific to your industry.

Risk factors in pubs, clubs, and gaming

The work at a venue is shaped by both the money-laundering risk itself and what triggers the due diligence you do around it. Four things make it distinctive:

• Cash, and often anonymity — transactions are cash-based and frequently anonymous, so the evidence about what happened often comes from CCTV footage rather than a system record.
• Gaming-specific play typologies — member play on electronic gaming machines (EGMs) has laundering patterns unique to it. The most common is minimal-play cash-out: a patron loads cash, plays little or none of it, then cashes out the balance as apparent winnings. Related patterns include buying other players' winning tickets and structuring payouts to stay under identification thresholds.
• Risk spotted on the floor — a venue is a physical space, so much of the risk is observed by staff and captured as an incident, alongside the responsible-gambling and responsible-service-of-alcohol (RSA) incidents your staff already record. Behaviour at the machine or cash desk worth recording includes a patron who:
  • feeds in significant cash and cashes out after little or no play
  • presents multiple tickets, or repeatedly collects payouts, just under the threshold where you'd take their ID
  • is reluctant to be identified, asks whether transactions are reported, or asks about limits
  • deals only with one staff member and avoids others, or offers tips to be left alone
  • plays with cash that's out of step with what you know about their means or occupation
• Due diligence triggers — every industry has to identify and risk-rate its customers; what's different at a venue is what sets that work off. Identification is prompted by events on the floor — a payout of $5,000 or more, a cumulative total for a patron, or suspicious behaviour regardless of amount — and risk rating draws on inputs specific to gaming, such as a patron's membership tier and status and their address relative to the venue. The profile and account changes worth watching include:
  • a change in a patron's membership tier — particularly a rapid one
  • a change of address
  • the size and volume of large payouts processed against them

How BNDRY fits the work

Each part of the work has a home in BNDRY. This is the shape of it at a glance; the rest of the guide works through the venue-specific parts in more detail.

Setting up BNDRY for your venue

A little configuration up front makes everything that follows fit your venue rather than a generic template.

• Hold patrons as Individual entities — a patron's profile is the durable record that their identification, screening, reviews, and any investigations all attach to. Set these up following how entities work.
• Add custom fields for what a venue tracks — a membership number that ties back to your gaming or membership system, a patron tier, or a venue-specific risk input. These are the data points a standard profile doesn't carry. See Designing custom fields.
• Configure risk levels to match your tiers — your OCDD cycle is driven by risk tier, so the tiers you set here are what later decide how often a patron is reviewed. See Configuring risk levels.
• Build the forms your processes need — an investigation form shaped around gaming events, an ECDD form for source of funds, an information-request form for members. See Designing form templates.

Key processes for a gaming venue

The mechanics of each process are covered in their own tutorials. What follows is what each one looks like when the customer is a patron on your gaming floor.

Members and visitors as entity profiles

BNDRY typically holds an entity profile for each of your members, and lets you add profiles for visitors worth tracking — anyone who isn't a member but where there are risk factors you want to keep a record of. Each profile is the durable record that a patron's screening, reviews, and any investigations attach to.

You don't have to build these by hand. Entity profiles can be created in bulk from your existing systems of record — your membership system, for example — by connecting it to BNDRY. BNDRY has pre-built connectors for common membership systems used in the gaming space, and it can keep member data in sync with those systems, so all your active members are always present and current in the platform. See Setting up entity profiles for how profiles and their data work, and Designing custom fields for capturing the venue-specific risk factors you want to track against a patron.

Ongoing due diligence (OCDD)

OCDD at a venue is primarily periodic and risk-tier-based: a higher-risk patron is reviewed more often than a lower-risk one, on a cycle you define. A change in a patron's risk tier is itself a prompt — if someone moves up a tier, their review cadence changes with them.

This is why the risk levels you configured earlier matter so much: they're the engine that drives the OCDD cycle. The review process itself follows the standard shape — see Conducting an Ongoing Customer Due Diligence review in BNDRY.

Running an investigation

A venue's investigations begin with behaviour and gaming activity — patterns of play and cash-out, the structuring patterns worth watching for such as amount clustering, velocity spikes, and split payouts, and incidents your floor staff observe directly.

Today, these observations and gaming events are entered into BNDRY manually to start an investigation — a staff member records what they saw and opens an investigation Workspace against the patron. Automated feeds from gaming-activity monitoring and incident-capture systems are planned, which will let these prompts flow into BNDRY directly rather than being keyed in.

Because you design the investigation form, it can capture the kinds of evidence a venue actually gathers — fields for uploading observation material such as CCTV footage or imagery, write-ups of what staff observed, and other research such as the output of source-of-wealth checks. Many AML programs also require ECDD on any entity that's been investigated, so you can add an ECDD form into the same investigation Workspace, letting the one Workspace encapsulate the whole process from the initial observation through to the enhanced due diligence and the determination. The investigation process itself — capturing the event, escalating for review, reaching a determination — is covered in Running an investigation in BNDRY.

Enhanced due diligence (ECDD)

AML programs typically require ECDD on any entity carrying a high-risk risk rating, and on any entity that's been the subject of an investigation or an SMR. For a venue, the substance of ECDD leans heavily on source of funds and source of wealth — understanding where a patron's money comes from when the volumes don't add up.

What earns a high-risk rating is unique to each program, but in gaming it's often a product of a patron's PEP exposure, their address, their membership tier and status, their level of play, and potentially their association with other high-level players. In BNDRY you can codify these parameters as a rules-based risk rating, so the rating is calculated automatically wherever the underlying data points are available in the platform. See Configuring risk levels to set this up, and Conducting Enhanced Customer Due Diligence in BNDRY for the process itself.

Requesting information from a patron

Requesting information from a patron is typically needed when source-of-wealth or source-of-funds information for ECDD can't be established from your other due diligence or research. In gaming, where you usually have an ongoing, in-person relationship with a patron, much can be resolved through that relationship — so the portal comes into its own for the situations that call for more detailed documentation or formal information.

BNDRY's secure portal handles that part: it gives the patron a branded, low-friction way to provide the documents or information you need, which lands back against their record. See Requesting information from a third party for how the portal works.

Other processes you can track in BNDRY

Beyond the core due diligence and investigation work, a venue can use BNDRY to keep a record of other processes against a patron's entity, so they build into the same history:

• Large payouts and CRT cashouts — record significant payouts and cash redemption terminal cashouts against the patron, along with any due diligence performed around them, so the activity and the work you did on it build into the patron's history.
• Risk rating changes and decision records — keep a record of when and why a patron's risk rating changed, and the reasoning behind the decision, so the rating is always backed by a documented rationale.
• Periodic reviews of top customers — track scheduled reviews of your highest-value or top-tier patrons, capturing what was looked at and what was decided each time.
• In-person chats or meetings — log conversations and meetings held with a patron, so context gathered face to face isn't lost and forms part of the record.
• Employee due diligence — record the due diligence performed on your staff, including employee training completed and police checks run, building an auditable history of who was checked and trained and when.
• Offboarding and continuation decisions — document a decision to offboard a customer, or to continue providing a designated service, together with the reasoning that supported it.

Related articles

• Conducting an Ongoing Customer Due Diligence review in BNDRY
• Conducting Enhanced Customer Due Diligence in BNDRY
• Configuring risk levels
• Designing custom fields
• Designing form templates