GOTHAM – Graphic Design Studio Sydney CBDAnti-Money Laundering/Counter-Terrorism Financing Policy - GOTHAM - Graphic Design Studio Sydney CBD

Anti-Money Laundering/Counter-Terrorism Financing Policy

Gotham Pty Ltd ABN 44 056 574 424

Compliance officer: Robert Harrison (Sole Director)


Established in 1987, Gotham Pty Ltd is a small Australian graphic design and visual communication company. With a legacy of over three decades, we have consistently delivered creative excellence to our clients. As a small business, we take pride in our niche specialization and unwavering commitment to quality and service.

Our Focus

Our core focus lies in providing graphic design solutions that empower and transform businesses. We are dedicated to working exclusively with registered Australian companies, fostering collaborations that contribute to the growth and success of our vibrant business community.

Our Team

At Gotham we have a dedicated team of professionals who bring passion, expertise, and innovation to every project. With a team of ten employees, we maintain a close-knit and dynamic work environment that thrives on creativity and professionalism. All team members are subject to a standard National Police Check upon employment.

Our Commitment to AML/CTF Compliance

As part of our commitment to ethical business practices, we have established this Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) policy. While our primary clientele consists of registered Australian businesses, we recognize the importance of adhering to AML/CTF regulations. This policy outlines our dedication to preventing money laundering and terrorism financing within our operations.


  1. Introduction

Gotham Pty Ltd (‘Gotham’) is committed to complying with the AML/CTF Act 2006 and its associated regulations. This policy outlines Gotham’s commitment to preventing money laundering and terrorism financing and defines the procedures we will follow to ensure compliance.


2. Risk Assessment

Gotham acknowledges that, while we primarily engage in business with registered Australian businesses holding Australian Business Numbers (ABNs), we must conduct a risk assessment to identify potential vulnerabilities to money laundering and terrorism financing.


3. Customer Due Diligence (CDD)

  • New Customer Verification:
    • Gotham will verify the ABN of all new customers and cross-check it with publicly available information.
    • Records of this verification will be maintained.
    • Gotham will not initiate a business relationship with any customer until their ABN is verified.
  • Ongoing Monitoring:
    • Gotham will periodically review the status of existing customers’ ABNs to ensure they remain registered.
    • Any discrepancies or changes in ABN status will trigger a review and potential re-verification.

4. Identifying Suspicious Transactions

Gotham is committed to remaining vigilant for any unusual or suspicious transactions, including but not limited to:

  • Frequent transactions just below the reporting threshold.
  • Rapid, unexplained changes in transaction patterns.
  • Transactions involving industries or businesses known for higher AML/CTF risk.

If any such transactions are identified, Gotham will promptly investigate and, if necessary, report them to AUSTRAC (the Australian Transaction Reports and Analysis Centre) as required by law.


5. Record-Keeping

  • Gotham will maintain accurate and up-to-date records of customer information, including ABNs and transaction details.
  • Customer records will be stored securely in our Filemaker database and MYOB accounting system.
  • Records will be accessible for auditing and reporting purposes.


6. Training and Awareness

Gotham will provide ongoing training and resources to employees to ensure they are aware of AML/CTF risks, procedures, and their responsibilities.


7. Review and Audit

The AML/CTF policy and procedures will be subject to periodic review and audit to ensure their effectiveness and compliance with the AML/CTF Act.


8. Reporting

Gotham will report any suspicious transactions or activities to AUSTRAC as required by law.


9. Resources

Adequate resources, both human and financial, will be allocated to implement and maintain this AML/CTF policy effectively.



Gotham Pty Ltd is dedicated to maintaining the highest standards of integrity and compliance with AML/CTF regulations. This policy represents our commitment to preventing money laundering and terrorism financing in our operations.