Summary
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.
Penalties
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.
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