Can my club accept a ‘Digital driver licence’ as part of identification for a large gaming win?

In short yes, but only if your Club’s AML/CTF program includes the ‘riskbased systems and controls’ required under the AML/CTF Rules for identifying patrons for large wins, AND the specific provisions needed to ensure the integrity of the identification accepted from the gaming patron for a large win.

Including digital driver licences in your club’s AML/CTF Program customer identification procedures
AUSTRAC considers digital driver licences issued by an Australian State or Territory government as ‘reliable and independent’ documents. Digital driver licences were launched across NSW and South Australia in 2019 and Victoria in 2024.

This means that digital driver licences can be used as part of a risk-based customer identification procedure for wins of $10,000 or more, if included in your club’s AML/CTF program. The AML/CTF Rules require risk-based systems and controls on when gaming staff or management must collect additional know-your-customer (KYC) information and / or take additional steps to verify it.

This may include requiring an additional identification document in addition to the driver licence (whether digital or not) as part of processing the cheque or EFT for the large win.

The program must also include systems to guide staff on how to deal with any discrepancies which arise in the verification process. Checking a digital driver licence and the customer identification process also operates alongside the AML/CTF requirements for ongoing gaming monitoring and ‘enhanced’ customer due diligence requirements (e.g., for ‘high risk’ patrons).

The importance of record-keeping
The AML/CTF Act requires gaming venues to keep records of identification information obtained from the customer and the procedure. The AML/CTF Rules also require that information obtained in the course of carrying out the customer identification procedure, must be kept by the regulated business in a form that enables them to:

Also, all personal information collected from gaming patrons for AML/CTF compliance is regulated by the Privacy Act 1988 and the Australian Privacy Principles.

How does the club ensure the integrity of a customer’s digital driver licence?
The AML/CTF Rules set out detailed criteria the AML/CTF Program must cover where any identification document is used to verify the identity of a gaming patron. These risk-based steps ensure the integrity of the process and can include checking the identification offered by the customer:

Each State or Territory government which issues a digital driver licence provides information for businesses on how to check the validity. This may involve ensuring the hologram displays correctly when the mobile phone is tilted (VIC and NSW), scanning a QR code (VIC and NSW) or barcode (S.A.) and using the ‘Swipe to refresh’ (VIC and NSW) or ‘shake to animate’  (S.A.) to ensure the ID is genuine and not a screenshot.

Conclusion
Digital driver licences can be accepted as part of your club’s identification procedure for large wins provided the AML/CTF Program is updated with the appropriate risk-based systems and controls relevant for your venue and you have an actionable plan for record keeping.

The detailed requirements of what your Club’s AML/CTF program must include under the AML/CTF Rules can be complex and will change in early 2026 following implementation of the AML/CTF reforms. If in doubt, seek professional advice.

Important terms
This update is a summary only and provided as a general information for clubs. It does not constitute legal advice or take into account the facts and circumstances of your gaming venue.

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