Appendices


Home Contact us Recruitment E-learning Information Publication Scheme	AUSTRAC Online login

Appendix A

Indicators of potential money laundering/terrorism financing activity

There are numerous indicators which may act as 'red flags' for reporting entities to identify potential money laundering or terrorism financing activity.

Although a single indicator does not necessarily indicate illicit activity, the existence of a 'red flag' indicator should encourage further monitoring and examination. In most cases it is the existence of multiple indicators that raises a reporting entity's suspicion of potential criminal activity, and influences their response to the situation.

Anti-money laundering and counter-terrorism financing (AML/CTF) officers should include these money laundering/terrorism financing indicators in staff training, and encourage their staff to use these indicators when describing suspicious behaviours for inclusion in suspect transaction or suspicious matter reports.

Money launderers and terrorism financiers will continuously look for new techniques to obscure the origins of illicit funds to give the appearance of legitimacy to their activities. AML/CTF officers should continually review their products, services and individual customers to ensure their internal AML/CTF systems and training remain effective.

The list below features indicators which appear within the case studies of this report, and should be treated as a non-exhaustive guide.

account activity inconsistent with customer profile
account operated by someone other than the owner
betting accounts with large deposits but with minimal betting activity
business activity inconsistent with business profile
cash payments for funds transfers
cash withdrawals from betting accounts in cheques and vouchers
client is a known frequent gambler/or high roller at a casino
client purchases or sells real estate above or below the market value while apparently unconcerned about the economic disadvantages of the transaction
co-mingling of illicit funds with legitimate sources of income
common bank accounts identify and link superannuants, facilitators and organisers
company account used for personal use
departure from Australia shortly after making funds transfers
frequent cash deposits made over a short period of time
frequent cheque deposits
funds transferred to overseas account but then withdrawn in Australia
funds transfers involving a tax haven*
funds transfers to numerous offshore jurisdictions with no business rationale
funds withdrawn from overseas account through ATMs in Australia
income inconsistent with customer profile
large cash deposit
large cash transactions conducted over a short period of time
large cash withdrawals with a bank cheque
large funds transfers after gambling activity
large international funds transfers
large number of accounts held by customer with the same institution
low-value property purchased with improvements paid for in cash before re-selling
multiple deposits made to same overseas account by different people
multiple funds transfers below AUD10,000
multiple funds transfers conducted from the same location
multiple funds transfers involving a high-risk drug country
multiple funds transfers to common beneficiaries
multiple geographical locations used to conduct transfers
multiple low-value funds transfers
multiple transactions occurring on the same day from different geographical locations
multiple transactions occurring on the same day to the same beneficiary
multiple transactions on the same day
numerous large deposits via ATMs
numerous loan applications for less than AUD25,000
outgoing transfer with corresponding incoming funds transfer - appears to be a 'u-turn' transaction
purchase of bank cheques
purchase of bank drafts by third parties
purchase of high-value assets (e.g. real estate, luxury vehicles)
purchase of travellers cheques with cash
same-day transactions at different geographical locations
same home address provided for funds transfers by different people
same or similar methods used to acquire more than one bank loan
significant cash withdrawals from superannuation accounts
similar transactions conducted over a short period of time
structuring of funds transfers or transactions
structuring of gambling purchases, payouts and withdrawals
third parties used to open bank accounts
transactions inconsistent with customer profile
unusual bank account activity into and out of superannuation account/s
unusual customer behaviour
unusual pattern of phone betting transactions
use of cash couriers
use of company accounts for personal use
use of false company
use of false identification documentation (to conduct transactions, etc.)
use of false invoices
use of family member accounts
use of gatekeepers (e.g. accountant)
use of inactive account
use of international credit card
use of internet shopping sites
use of multiple accounts for deposits
use of multiple remittance service providers to transfer funds to common overseas beneficiaries
use of multiple remitters in the same geographical location
use of stored value cards
use of student accounts after their departure from Australia
use of third parties to conduct international funds transfers
use of third parties to conduct transactions
use of third party accounts
use of variations when spelling names/addresses
value of funds transfers inconsistent with customer profile
withdrawing all, or nearly all, funds from an account within a short period of time.

* The Australian Taxation Office maintains a list of jurisdictions it considers to be tax havens. This list is available on the Tax Office website at www.ato.gov.au, and continues to be reviewed and updated as circumstances change.

Quicklinks

AUSTRAC Typologies and Case Studies Report 2009 (PDF, 4MB)

Typologies and Case Studies Report 2009