We have created suspicious activity indicators to help you identify potential money laundering, terrorism financing and other serious criminal activities. These indicators can inform your transaction monitoring alerts that trigger further review.
To complement these indicators, you must also ensure your transaction monitoring systems alert you to unusual, large or complex transactions or patterns of transactions.
If you suspect a customer or a transaction involving your customer is linked to a crime, submit a suspicious matter report (SMR) to AUSTRAC within the required timeframes. This includes where you reasonably suspect a person:
- is committing a crime
- is not who they claim to be
- could be the victim of a crime.
On their own, one of these indicators may not suggest suspicious activity. If you are unsure whether there are reasonable grounds for a suspicion, you should conduct further monitoring and examination, including applying enhanced customer due diligence (ECDD) measures. If you have clear and reasonable grounds for a suspicion, you must submit a suspicious matter report (SMR) to AUSTRAC.
For more information on complying with your reporting obligations, see our suspicious matter reporting reference guide and suspicious matter reporting checklist.
This indicators list is not exhaustive. You should consider other indicators specific to your business’s individual risk profile and circumstances.
On this page
Customer identification and behaviour
Customer identification indicators
A customer:
- provides identification information that is false, misleading, vague, or cannot be verified
- refuses and/or is reluctant to provide identification information or documents
- is identified in adverse media
- has sources of wealth or sources of funds that are unexplained and/or inconsistent with their profile
Customer behaviour indicators
A customer:
- with no known or apparent relationship shares funds with another customer
- makes an unusual enquiry to staff about whether they report to government authorities. For example, AUSTRAC, the Australian Taxation Office or law enforcement agencies
- enquires about transaction limits or requests their transaction not be reported
- and/or their gaming activity is the subject of law enforcement enquiries
- appears nervous, overly defensive, or evasive when questioned
- appears coached or rehearsed when answering questions
- uses arbitrage betting strategies to minimise losses
- appears to be directed by a third party
Money laundering
Money laundering indicators
A customer:
- purchases winning betting slips from other customers and presents them as their own
- structures cash bets to fall below the $10,000 reporting threshold (this is known as structuring)
- uses third party individuals (agents) to place bets on their behalf, in an attempt to anonymise their betting
- refuses or is hesitant to provide evidence as to the source of funds or wealth for their betting
- splits large cash deposits and/or withdrawals into multiple smaller ones below the$10,000 reporting threshold (structuring)
- sends or receives funds from third parties
- makes multiple cash deposits followed by a cheque withdrawal/s
Terrorism financing
Terrorism financing indicators
- A customer is matched through screening against an Australian or international sanctions list.
- Open source information identifies a customer has links to known terrorist organisations or terrorism activities
- Open-source research indicates a customer displays extremist ideologies (social, political, environmental etc.).
Related pages
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.