Money Laundering Process

The money laundering process is how proceeds of crime are converted into funds that can be used openly without attracting attention.

It is conventionally described in three stages.

• Placement. Getting the money into the financial system. Cash deposits, purchases of goods, or a business that handles cash legitimately.
• Layering. Moving it through transactions and entities to obscure its origin. Transfers, company structures, trusts and cross-border movement.
• Integration. Bringing it back as apparently legitimate wealth. Property, investments, or payment for services.

The point most staff miss is that a single business usually only ever sees one stage. A real estate agency sees integration. A remittance service sees placement or layering. Recognising which stage your business is exposed to narrows what you are looking for considerably.

Work out which stage your business is exposed to before you choose what to train people on. 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 AML/CTF articles.