The Star, Suncity and another $260 million bill

A $100 million fine was supposed to change things

In October 2022, NSW fined The Star $100 million, suspended its Sydney casino licence and appointed a manager to oversee the business. The first Bell inquiry had found the operator unsuitable to hold its licence, but the intervention gave it an opportunity to put its operations in order while the casino remained open.

Queensland imposed another $100 million penalty that December following its own inquiry. It also appointed a special manager and ordered licence suspensions, deferring their commencement to give the company time to address its failures.

Two years later, a second NSW inquiry resulted in a further $15 million fine. Closer supervision had prevented the type of misconduct exposed in the first inquiry, the regulator said, but significant shortcomings remained in areas The Star claimed to have fixed.

The company had been fined and placed under independent supervision, yet the regulator was still finding a gap between the repairs described to it and the business it inspected.

On 28 October 2026, the Federal Court imposed a further $260 million penalty for breaches of Australia’s anti-money laundering and counter-terrorism financing laws. The judgment concluded AUSTRAC’s proceedings over historical conduct, with the court taking earlier penalties for overlapping conduct into account. It was another bill for the earlier failures, rather than a finding that the same activity had continued throughout the intervening years.

AUSTRAC had sought $400 million. The Star argued for $100 million, warning that a larger penalty could force it into liquidation. The court settled on $195 million for Sydney and $65 million for Queensland, payable in four instalments over 19 months.

A $300 million rescue package had already been put forward in April 2025 to keep the business out of administration. By the time the federal penalty arrived, The Star’s ability to pay had become a substantial part of the argument.

The rules outside Salon 95

Years before those arguments reached court, Suncity was bringing high-value gamblers to The Star Sydney. The junket operator had exclusive use of Salon 95, a private gaming room where its agreement with the casino prohibited cash transactions.

CCTV footage played to the NSW inquiry showed Suncity staff bringing sports bags to the service desk and unpacking bundles of $50 notes. Other footage showed cash arriving in a plastic bag and a gambler receiving a substantial payout in a brown paper bag. Evidence to the inquiry indicated that the transactions were widely known to be happening, despite what the agreement said.

The casino had a rule governing the room. Suncity’s staff appeared to be working to a different understanding.

A profitable distance from the customer

Junket operators organise visits by wealthy gamblers, giving casinos access to customers they might otherwise struggle to attract. The intermediary helps arrange the business, but also puts distance between the casino and the people whose money reaches its tables.

That distance matters when someone deposits cash or moves money on another person’s behalf. The casino still needs to understand who is involved and where the funds came from.

AUSTRAC described The Star allowing suspicious junket activity to continue without effective intervention, despite its concerns. Some cash deposits and third-party transactions took place without the third party’s identity being recorded.

There was considerable money in preserving the relationships. The court put junket revenue at more than $1.4 billion over the relevant period, with junket profits exceeding $100 million in the pre-COVID years. Those figures did not measure the benefit from the breaches, but they illustrated the commercial attraction of business conducted with insufficient scrutiny.

Please charge it to the room

Elsewhere in the business, customers used China UnionPay cards to obtain money for gambling, a use UnionPay prohibited. The Star processed the transactions as hotel expenses, and more than $900 million passed through the arrangement.

According to the Bell review, the supporting paperwork could include a room number and arrival and departure dates. Customers who had not stayed at the hotel could be assigned a dummy room, saving their absence from interfering with the explanation.

Anyone reviewing the payment therefore had more than an unexplained transaction to contend with. They had a transaction accompanied by a misleading account of its purpose. Checking that the paperwork existed would not establish whether it described what had actually happened.

Other casinos had been here before

Crown Melbourne and Crown Perth received a combined $450 million AML penalty in July 2023. Crown had continued dealing with a major junket operator despite knowing of allegations connecting it to organised crime.

In one operator’s private gaming room, at least 75 suspicious incidents involved around $23 million in cash. Crown also failed to monitor billions of dollars in transactions appropriately, including international payment flows.

SkyCity Adelaide followed in June 2024, with a $67 million penalty and $3 million in costs. It had failed to carry out required checks on 121 customers, including some it knew were of interest to law enforcement. High-risk customers moved millions through the casino in circumstances that left the source and ownership of the funds unclear.

The penalties reflected the circumstances of each case, so their size should not be mistaken for a ranking of misconduct. What the cases shared was high-risk business continuing without adequate controls, even where information already available should have prompted closer scrutiny.

The executives received separate bills

In June 2026, proceedings brought by ASIC reached former CEO Mathias Bekier and former chief legal and risk officer Paula Martin.

Bekier was ordered to pay $700,000 and disqualified from managing corporations for six years. Martin received a $400,000 penalty and a seven-year disqualification. The findings concerned their duties under the Corporations Act and their handling of serious risks, including money laundering and criminal activity, rather than criminal money-laundering convictions.

Both filed appeals in July 2026. ASIC’s case against seven former non-executive directors was dismissed, an important distinction in a story where the company’s failures and each individual’s legal responsibility are easily conflated.

The explanation was part of the problem

The UnionPay transactions came with descriptions that appeared to explain the payments. Suncity operated under an agreement that appeared to constrain its activities. Neither necessarily provided a reliable account of the business being conducted.

A hotel charge could explain an entry on a statement while concealing the fact that the money funded gambling. The agreement governing Salon 95 could prohibit cash transactions while bags of notes continued arriving at the desk.

For a professional firm, the same gap can emerge in less conspicuous circumstances. A property deposit may arrive from someone other than the buyer, supported by an explanation that nobody has tested. A company may receive funding that is difficult to reconcile with its business, while a trusted referrer deals with every question on the client’s behalf.

The documents can be genuine without adequately explaining the activity. Establishing that a company exists, or that a payment came from a particular account, leaves open the question of why the money is there.

Five warnings that should have changed the relationship

1. An intermediary stood between the business and the customer

An introducer can make a relationship commercially attractive while making the people and money behind it harder to understand.

The control that matters: establish who the customer is and understand the intermediary’s involvement, including whose money is being used. Reassurance from the person bringing the business should not substitute for the checks it requires.

In your firm: a referrer handles the relationship and resists requests for direct contact with the client or supporting evidence.

2. Adverse information did not change the relationship

A screening result has little value if the assessment never reaches the person deciding whether to accept the next instruction.

The control that matters: assess credible adverse information and document how it affects the decision to proceed. Where concerns remain unresolved, the relationship should not continue on the assumption that somebody else has dealt with them.

In your firm: a screening result is repeatedly dismissed without a documented assessment, while the client continues instructing on new matters.

3. The payment description concealed its purpose

The UnionPay arrangement showed how a plausible label could obscure what a transaction was actually doing.

The control that matters: reconcile the payment with the underlying activity, investigating discrepancies and assessing whether the circumstances give rise to a reporting obligation.

In your firm: a trust account receipt or settlement payment has an explanation that does not fit the client’s instructions or the transaction documents.

4. The source of the money remained inadequately explained

Cash is not inherently criminal, just as a bank transfer does not establish that funds have a legitimate origin.

The control that matters: obtain an explanation and supporting evidence proportionate to the risk. Where the evidence conflicts with the account given, resolve the discrepancy before treating the check as complete.

In your firm: a property deposit comes from an unexplained third party, or a company receives funding inconsistent with what is known about its owners and business.

5. Commercial importance weakened scrutiny

A valuable relationship can acquire informal exemptions, with unanswered questions carried forward because nobody wants to disrupt the work.

The control that matters: give compliance concerns an effective route to someone with the authority to pause work, and record the basis for any decision to proceed.

In your firm: a major client’s files receive less scrutiny because a partner considers the relationship too important to disrupt.

What happened after the warning?

Since 1 July 2026, AML/CTF obligations have applied to businesses providing specified services in the legal, accounting, real estate and other newly regulated sectors. Coverage depends on the services provided, rather than the profession alone.

For those businesses, The Star’s case is difficult to reduce to a lesson about spotting red flags because some of the activity was already known. The more useful question is why that knowledge did not sufficiently change the way the business operated.

The person approving a client or matter needs to see concerns raised elsewhere in the firm, including questions left unanswered on previous instructions. A decision recorded only in an email or remembered by the relationship partner may be of little use to the next person handling the file.

First AML brings screening and due diligence evidence together with approval workflows in one client record, helping the person responsible understand what remains unresolved and the basis on which earlier decisions were made.

The Star also shows why a firm must test whether its controls work as described. After the first inquiry, the company had years to demonstrate improvement under supervision. The second inquiry still found shortcomings in areas it claimed to have repaired.

The agreement for Salon 95 said cash transactions were prohibited. The subsequent history showed how much could depend on checking whether the business followed its own account of itself.