Terms of Service
1. Acceptance of Terms
By accessing or using the Venue Axis platform, the authorised representative of the venue accepts these Terms on behalf of the venue and its authorised staff. "Venue Axis" refers to the operator of the Venue Axis compliance platform (legal entity details to be inserted before publication). "You" and "your venue" refer to the registered club or venue accessing the platform.
If you do not accept these Terms, do not access or use the platform.
2. The Reporting Entity Relationship
This is the load-bearing section of these Terms. It exists because of a specific regulatory context under Australian law, and every club using Venue Axis should read it carefully.
Your venue is the AML/CTF reporting entity
Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”), a registered club that provides a designated service — including gaming machine services — is a reporting entity (as defined in ss.5 and 26F of the AML/CTF Act). As a reporting entity, your venue bears statutory obligations to AUSTRAC including:
- Maintaining an AML/CTF program (Part 7 of the AML/CTF Act)
- Conducting customer due diligence (CDD) on patrons where required
- Submitting Threshold Transaction Reports (TTRs) and Suspicious Matter Reports (SMRs) to AUSTRAC
- Designating an Anti-Money Laundering Compliance Officer (AMLCO) under s.26J
- Maintaining records for the minimum periods required by the Act and AUSTRAC Rules
These obligations are your venue's obligations. They cannot be outsourced, delegated, or transferred to Venue Axis or any other vendor. AUSTRAC's enforcement position — reinforced by proceedings against clubs and their technology providers — is that a reporting entity remains accountable for its AML/CTF obligations regardless of what tools or services it uses to support compliance.
Venue Axis is a compliance vendor
Venue Axis is a compliance software vendor. Venue Axis provides technology tools to help clubs organise, record, monitor, and report on compliance events. Venue Axis does not:
- Undertake your venue's AML/CTF obligations. Venue Axis is not itself a reporting entity on your behalf.
- Substitute for your venue's AMLCO. The AMLCO is a natural person designated by your venue under s.26J of the AML/CTF Act; the AMLCO's responsibilities remain with that person, not with Venue Axis.
- Make compliance decisions on your venue's behalf. CDD determinations, SMR lodgements, and TTR submissions are decisions made by your venue's authorised staff; Venue Axis supports and records those decisions.
- Provide legal or compliance advice. Venue Axis is software, not a lawyer or a compliance consultant.
Using Venue Axis does not satisfy your venue's compliance obligations. Your venue must independently ensure that its AML/CTF program, staff training, CDD procedures, and reporting obligations meet the requirements of the AML/CTF Act, the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (as amended), and any AUSTRAC guidance applicable to your operations.
3. Venue Axis's Role
What Venue Axis provides
- Compliance workflow tooling: structured recording of compliance events including incidents, welfare checks, inspector arrivals, and machine malfunctions
- CDD and threshold monitoring support: tools to help staff identify when a patron's transactions approach or exceed the $10,000 TTR threshold, and structured recording of CDD interactions; final determination of whether a transaction is reportable remains with your staff
- SMR and TTR drafting assistance: structured forms and templates to help staff prepare Suspicious Matter Reports and Threshold Transaction Reports for review and lodgement by authorised staff; Venue Axis does not lodge reports without explicit staff approval
- Training register management: tracking of staff training completion and records; Venue Axis does not itself deliver training
- Audit log and evidence trail: timestamped records of all compliance events and staff actions, available for regulatory inspection
- Document generation: assistance generating AML/CTF program documents, risk assessments, and implementation plans for review and adoption by your venue
What Venue Axis does NOT undertake
- Your venue's AML/CTF obligations under the AML/CTF Act or AUSTRAC Rules
- Lodgement of any report to AUSTRAC without explicit review and approval by your venue's authorised staff
- AMLCO duties (these remain with the natural person designated under s.26J)
- Compliance decisions or legal advice
- Sanctions-screening at the entity level (Venue Axis supports the recording of screening results; your venue determines how to act on them)
- Any obligation under the Gaming Machines Act 2001 (NSW) or Liquor & Gaming NSW requirements
4. AMLCO Designation
The AML/CTF Act requires each reporting entity to designate a natural person as its AMLCO (s.26J). Your venue is responsible for making and maintaining that designation. Venue Axis tooling includes features to support the AMLCO's workflow (reviewing compliance events, approving reports, tracking training) but these features are support tools, not a substitute for the AMLCO.
Venue Axis does not act as AMLCO for any venue. Venue Axis does not advise your venue on whether a specific person meets the requirements for designation as AMLCO.
5. Data and Records
Your venue is the APP entity (under the Privacy Act 1988 (Cth)) primarily responsible for personal information collected from your patrons and staff in the course of your venue's operations. Venue Axis processes that information on your venue's behalf as a service provider.
The full details of how personal information is handled — what is collected, why, how long it is retained, and how your venue and patrons can exercise privacy rights — are set out in the Venue Axis Privacy Policy and the Data Processing Agreement between Venue Axis and your venue.
Your venue is responsible for maintaining AML/CTF records for the minimum retention periods required by law (generally 7 years for AML/CTF records; 3 years for gaming incident records). Venue Axis provides export tools and supports your venue in meeting these obligations, but your venue is ultimately responsible for compliance with applicable record-keeping requirements.
6. Service Limitations
Venue Axis is software, not legal advice. Nothing in the platform, its documentation, or these Terms constitutes legal advice and should not be relied upon as such. Your venue should seek independent legal counsel as needed regarding your specific compliance obligations.
Venue Axis makes no representation that use of the platform satisfies any specific regulatory obligation. Regulatory requirements change, and your venue is responsible for ensuring its compliance program remains current.
The platform is provided on a best-endeavours basis with target availability levels set out in the service agreement between Venue Axis and your venue. Venue Axis is not responsible for any regulatory consequence arising from a system outage or unavailability, and your venue should maintain offline procedures for recording compliance events during any outage.
7. Liability
To the extent permitted by law, Venue Axis's total aggregate liability to your venue under or in connection with these Terms or the use of the platform is limited to the fees paid by your venue in the 12 months preceding the event giving rise to the claim.
Venue Axis is not liable for any regulatory penalty, enforcement action, or compliance failure arising from your venue's failure to meet its obligations under the AML/CTF Act, the Gaming Machines Act 2001 (NSW), or any other applicable law. Venue Axis is a compliance vendor, not a guarantor of your venue's compliance posture.
Nothing in this clause limits liability for fraud, wilful misconduct, or any liability that cannot be excluded by law (including under the Australian Consumer Law).
8. Governing Law
These Terms are governed by the law of New South Wales, Australia. Each party submits to the exclusive jurisdiction of the courts of New South Wales.
9. Updates to These Terms
- Material changes will be communicated to venues with at least 30 days' notice before taking effect
- Minor changes (clarifications, formatting, placeholder details) may be made without advance notice
- The “Last updated” date at the top of this page is updated for every change
- Continued use of the platform after the effective date of a material change constitutes acceptance of the updated Terms
- Prior versions are available on request
Contact
For questions about these Terms: