Reporting suspicious matters
Reports of suspicious matters have been the catalyst for many significant investigations conducted by AUSTRAC's national security, law enforcement, revenue collection and social justice partner agencies. The prompt reporting of suspicious customer activity by reporting entities has enabled AUSTRAC to immediately refer the information to relevant agencies, leading to successful law enforcement outcomes. A number of the investigations included in this Typologies and Case Studies Report were initiated as a result of high-quality, timely and relevant reports of suspicious matters.
The grounds for suspicion have often provided valuable leads to investigators to assist in the identification of illegal activity. Some of the more common themes or indicators reported include:
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customers who avoid, or attempt to avoid, transaction reporting obligations
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customers who use multiple reporting entities and/or branches to avoid arousing suspicion and detection
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customers who undertake transactions that appear inconsistent with their profile
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customers who conduct multiple transactions within a short time frame
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customers who exhibit irregular behaviour or patterns of transactions
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use of currency that is in an unusual condition (for example, dirty, wet, smelly)
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frequent exchanges of currency denominations (for example, exchanging $20 notes for $100 notes) or currency types (for example, exchanging Australian dollars for euros) where such exchanges are inconsistent with the customer's profile
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regular transfers of funds between a customer's personal account and a business or commercial account
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international funds transfers to high-risk countries, where such transactions are inconsistent with the customer's profile. High-risk countries include:
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countries commonly associated with the production or transport of drugs
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countries known to be tax havens*
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countries associated with phishing scams and card skimming
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customers who regularly use stored value cards and frequently add value to the card below the card's threshold limits, particularly when the card is used domestically.
Accurate and timely reporting of suspicious matters is underpinned by effective 'know your customer' information collection and verification processes, a customer due diligence program and the vigilance of reporting entities. Staff training and awareness together with intuitive transaction monitoring systems are critical to the detection of suspicious activities and their subsequent reporting to AUSTRAC and law enforcement agencies.
* 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.
Law enforcement agency quotes on the value of reports of suspicious matters
'This report will assist in a matter in which the suspected offences are money laundering, welfare fraud and tax evasion.'
'Based on the suspect transaction report (SUSTR), the subject of the investigation appears to have a lengthy history of fraudulent activity.'
'I have found this SUSTR very useful - the person is well known to us and this change in financial pattern is of great interest to us.'
'This SUSTR…was an excellent referral which helped us recognise a suspect transaction pattern.'