The customer is not necessarily the individual making the threshold transaction. If this is the case your TTR must state this, and include details about the individual making the transaction. This includes individuals who are:
- an employee acting on behalf of the customer (such as depositing business takings)
- conducting the transaction on behalf of an organisation such as a trust or association which is not the customer
- conducting the transaction on behalf of a family member or friend.
Carefully check whether the individual conducting a threshold transaction is the customer of the designated service. For example, you could check to see if an individual making a deposit into an account is the account holder.
It’s reasonable for you to accept that the individual is the customer unless you have good reason to believe otherwise. This might be because, for example:
- the individual tells you directly they aren’t the customer
- the account is in the name of a business or organisation
- you notice an obvious difference in age or gender between the individual making the transaction and the personal details of the account holder
- the type or size of transaction isn’t consistent with the customer’s previous financial activity or their financial profile
- the transaction happens at a location not normally associated with the customer, such as interstate.
If you don’t know whether the customer or someone acting on their behalf made a transaction, you must fill in the TTR form as if the individual was the customer and supply the details accordingly.
You can use information you have previously collected from the individual to complete the TTR.
Identifying a customer who is not present
When the individual making the threshold transaction is not the customer of the designated service, the customer is often not present when the transaction is made. In some cases, you won’t know the customer because you haven’t provided a designated service to them before and therefore haven’t identified them. In these cases, you may consider collecting identifying information about the customer from the individual who wants to make the transaction and verifying this information before you provide the service.
If you can’t collect or verify the information, you may decide not to provide the service.
When you don’t have to provide an individual’s details
You don’t have to include the details of the individual who made the transaction in a TTR if:
- the transaction wasn’t made face-to-face (for example, a deposit made through a night safe or express deposit box)
- the transaction involved an individual from a cash courier service.
Instead you must give AUSTRAC a statement about the circumstances of the threshold transaction, as well as the customer details.
When the customer making the transaction is a politically exposed person (PEP)
If your customer is a high-risk politically exposed person (PEP), you must:
Enhanced customer due diligence procedures include considering whether or not you should process particular transactions, and whether existing customer identification information you have on record should be updated or re-verified.
High-risk PEPs include all foreign PEPs, and those domestic or international organisation PEPs you identify as a high risk of money laundering or terrorism financing. Note: immediate family members or close associates of PEPs are also considered to be PEPs.
Multiple signatories on an account
If there are multiple signatories to an account, you are only required to report the details of the individual signatory who authorised the threshold transaction. This is because some accounts (such as corporate accounts) may have many signatories and it can be impractical for a reporting entity to collect the details of all the individuals. However, AUSTRAC can ask you to give us information about any other signatory to the account.