Using cash from his retail business, the offender systematically structured deposits totalling over A$2.5 million in an attempt to avoid transaction reporting requirements and evade tax.

What to look out for

  • Large cash deposits into an account, including a term deposit account, above the customer's normal transactional activity.
  • Customer advising that a large cash deposit is the result of stockpiling cash.
  • Structured cash deposits into personal credit card accounts on the same day.
  • Regular structured cash deposits or deposit of personal cheques drawn on customer’s accounts at another bank.
  • Cash exchanged for the same amount in A$100 notes.

The crime

The offender stockpiled cash from his retail business, and systematically structured deposits by dividing large sums into smaller deposits to avoid threshold reporting requirements.  

After a bank submitted a suspicious matter report (SMR), AUSTRAC alerted police to the offender’s suspicious financial activities and they investigated. The investigation found that the offender made 28 cash deposits of A$9500 into his personal credit card account, often making two separate cash deposits on the same day. The offender also made regular structured cash deposits into his personal bank account. Over five years, the offender structured deposits totalling more than A$2.5 million.

Police searched the offender’s residential and commercial properties and seized A$70,000 in cash, unlicensed firearms and ammunition. Police also took control of four properties and funds in an account, worth a combined A$7 million.


The offender was convicted of structuring. He was fined A$7000 and ordered to pay a penalty of over A$1 million. He was also convicted of firearm-related offences.

How business reporting helped

The investigation was triggered by an SMR submitted by a bank. The offender visited the bank to deposit over A$1 million in cash and a personal cheque for A$570,000 into his term deposit account. When bank staff questioned him about the origin of the money, he said it came from his business, and that he had stockpiled it to avoid paying tax. The SMR also noted the term deposit had been operating for over two years and had a balance of A$2.1 million, mostly from cash deposits. The bank’s SMR triggered AUSTRAC’s automated monitoring systems, and AUSTRAC forwarded the SMR to police.

Industry also submitted threshold transaction reports (TTRs) indicating the offender had made more than A$2.5 million in cash deposits over five years.

AUSTRAC’s role

AUSTRAC’s analysis revealed that the offender had made regular structured cash deposits into his personal credit card account, exchanged A$15,000 cash into A$100 notes, and made large cash and cheque deposits into his term deposit account simultaneously. 

The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.

Last updated: 5 Apr 2023
Page ID: 124

Was this page helpful?

Was this page helpful?
Please note that feedback you provide here will be used only for the purpose of improving our website. If you have a specific question about your AML/CTF obligations, please contact us.