Money Laundering Process Stages

The money laundering process stages are usually taught as a general model. The useful question for a reporting entity is narrower. Which stage will we actually see?

Placement is most visible where cash enters. Banking, remittance, gaming and cash-intensive retail.

Layering shows up where structures and transfers are created. Professional services, accounting, company formation and trust work.

Integration is where value is converted into assets. Real estate, luxury goods, vehicles and high-value dealing.

That mapping should drive your training content. An agent trained mainly on cash deposit red flags has been given the wrong stage, and will not recognise an unusual funding source or a buyer acting for an undisclosed third party.

Work out your stage first, then choose the indicators to match it. Generic AML content covers all three stages shallowly and leaves staff unable to recognise the one they will actually meet.

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

See Sentrient’s AML/CTF training for real estate and AML/CTF for professional services.