Summary
An Australian law enforcement agency investigated an accountant believed to be involved in money laundering. AUSTRAC information linked the offender to multiple companies and structured cash deposits.
What to look out for
- Multiple domestic transfers to third-party accounts.
- Multiple international funds transfer instructions (IFTIs) which are inconsistent with the customer’s established profile.
- Structured cash deposits from third parties into a bank account.
- Structured financial transactions in personal and business names.
The crime
Over two years the offender, an accountant, received more than 80 structured cash deposits and a small number of cheques into his account. He regularly consolidated the funds from these deposits and transferred them electronically to third-party domestic accounts. Authorities believed he received a percentage of the funds he transferred as a commission for his services.
Although the exact source of the funds the offender laundered is unknown, authorities identified a possible relationship between the funds and the illegal drug trade into Australia.
AUSTRAC’s information linked the offender to approximately 50 companies and revealed the structured cash deposits into his account were made on behalf of both companies and individuals.
Our analysis showed that the offender also transferred more than A$700,000 to Hong Kong and New Zealand. The funds were transferred from the offender’s accounts to overseas business accounts in amounts between A$400 and A$50,000. For some transactions the offshore recipient businesses shared the same name as businesses operated by the offender in Australia.
The offender was charged for providing incomplete information in relation to a financial transaction.
Penalties
The offender pleaded guilty and was sentenced to nine months imprisonment with a two year good behaviour bond.
How business reporting helped
Reporting entities provided key information including IFTIS and four suspicious matter reports (SMRs) detailing the offender’s the offender’s structured cash deposits.
AUSTRAC’s role
AUSTRAC’s discovery of the offender’s links to companies and individuals and our analysis of the transactions were crucial to the investigation and the offender’s conviction.
This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened.
The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.
This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.