Money Laundering Activity

Identifying money laundering activity is easier across a pattern than in one transaction, and staff usually only see one. Four features make a single transaction worth an internal report.

No commercial logic. The arrangement costs the customer money or effort and achieves nothing obvious. This is the strongest single indicator.

Reluctance to explain. Evasiveness about source of funds, or an explanation that changes when questioned.

A third party in the background. Someone else providing funds, giving instructions or benefiting, without being the customer.

Unusual urgency or indifference to cost. Willingness to accept a worse outcome to complete quickly.

None of these prove anything on their own. Staff are not being asked to reach a conclusion about a customer, only to pass an observation on internally so someone with the full picture can assess it.

AUSTRAC publishes guidance for reporting entities. This is general information rather than legal advice, and obligations vary by state and territory.

See Sentrient’s AML/CTF course and incident reporting software.