The typology outlined below is intended to inform stakeholders about one technique which criminals have used to launder the proceeds of their illicit activity.
Law enforcement investigations identified a number of instances where individuals (known as ‘third-party cash couriers’) were depositing large amounts of illicit cash into the bank accounts of remittance businesses registered with AUSTRAC. (32, 33).
In an attempt to make the deposits appear legitimate, the third-party cash couriers are instructed to claim they are employees of the registered remitter. This cover story is used to explain to the bank the (legitimate) source of the cash (34).
Investigations revealed that another individual (the recruiter), who may be a member of an organised crime group, is responsible for coordinating the various cash couriers depositing cash into the remitters’ accounts.
Money laundering typology
The use of third-party cash couriers to deposit illicit cash into the bank accounts of remitters may involve the following:
- A job advertisement is placed online or in a local paper for a role as an ‘office assistant’.
- The cash courier responds to the advertisement and is offered the job of depositing cash into the accounts of remitters. When recruited, the cash courier may not be aware of the true (illicit) source of the funds.
- The cash courier meets the recruiter at the recruiter’s office and the two visit various banks.
- The recruiter carries the cash until they reach the bank and then hands the cash over to the cash courier to deposit. The cash is generally carried in a shopping bag to avoid suspicion.
- The recruiter instructs the cash courier to deposit the cash into specific banks and branches and provides them with completed deposit slips to use for each transaction. The cash is usually deposited in amounts of less than AUD10,000 in order to avoid suspicion.
- If questioned, the cash courier is instructed to advise bank staff that they are an employee of the remitter.
- Deposits are made at different banks and branches across central business district (CBD) locations.
- The cash courier may also be instructed to use the services of different banks in various suburbs outside the CBD in an attempt to reduce the chances of detection.
- Once the cash is deposited, the recruiter will contact the remitter and provide details of where to send the funds overseas. The remitter instructs the bank to send the funds via an IFTI to a beneficiary overseas.
- In some cases, the remitter is unwittingly involved and unaware that their bank accounts and services are being used by criminal groups to transfer illicit cash.
- The recruiter may also ask the cash courier to open accounts using the cash courier’s own identification (for example, a drivers licence) and give the recruiter the authority to operate the account. The account is established to receive cash deposits from the recruiter. The recruiter may then transfer the funds in the account to the remitter’s account, to be subsequently transferred offshore.
- The cash courier is paid one per cent of the total cash they have deposited after the deposit is made.
The following indicators may assist reporting entities to identify potential money laundering activity involving third-party cash couriers depositing cash into remitter accounts.
- Cash deposits conducted by a third party where the reporting entity has doubts about the validity of the identification document used by the third party
- Depositor unable to produce evidence of employment or address/contact numbers
- Depositor claims to be an employee of more than one remitter
- Depositor unable to specify where they collected the cash as it is given to them by someone else
- Individuals make regular trips to bank branches to deposit large amounts of cash into remitter accounts
- Large cash deposits being made into multiple bank accounts belonging to remitters
- Same-day international funds transfers occurring through multiple remitters to the same overseas beneficiary
- Sudden increase in cash deposits into remitter bank accounts
- The same individual making large cash deposits at several bank branches or different banks across CBD locations
- Use of third parties to make large cash deposits
Law enforcement has previously detected a variation of this method whereby third parties are recruited from overseas. The recruited couriers are used to smuggle significant amounts of illicit cash into Australia or, once in Australia, used to deposit illicit cash into accounts for subsequent transfer overseas. This method is outlined in more detail in the AUSTRAC typologies and case studies report 2012 (35).
Previous reports in the AUSTRAC typologies and case studies series have covered a wide range of money laundering methodologies and financial crimes.To find out more about these crimes and methodologies, refer to AUSTRAC’s typologies and case studies previous reports.
- See the Glossary for a definition of ‘cash couriers’.
- See the Chapter 5 of the AUSTRAC compliance guide on the AUSTRAC website for more information on remitter registration.
- Dealing in the proceeds of crime is an offence under sections 400.3 to s400.9 of the Criminal Code Act 1995.
- AUSTRAC typologies and case studies report 2012, p. 13.