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Fintel Alliance helps banking staff identify illegal phoenix activity

30 October 2019

Fintel Alliance, an AUSTRAC initiative, today released a report to help industry identify and report on the common indicators of illegal phoenix activity. 

While the report examines illegal phoenix activity in the labour hire industry, the indicators are also relevant to other businesses that mainly pay their staff and suppliers in cash. 

If you work in AML/CTF compliance, this Fintel Alliance report will help you more quickly identify and report on suspicious matters that relate to illegal phoenixing. 

Download and share the Fintel Alliance illegal phoenix activity report

When to report a suspicious transaction to AUSTRAC

The key indicators of illegal phoenix activity include a customer’s demographic, financial activity, bank account history and company registration. 

On their own, these indicators may appear normal. However, if you notice a combination of indicators, consider submitting a suspicious matter report to AUSTRAC.  

 Common indicators of illegal phoenix activity

Demographic indicators

Financial activity indicators Bank account indicators Company registration indicators
  • male
  • occupation - Director
  • same/similar ethnicity
  • network operates in the same geographical location
  • network companies have common contact details
  • residential addresses
  • regular cash withdrawals from same branches
  • structured withdrawals on same or consecutive days
  • minimal business type expenses
  • most funds spent, little left to cover expenses
  • compulsory financial obligations payments are minimal or not being made
  • sole account signatory
  • multiple accounts with various banks
  • phoenixed company account remains dormant
  • similar transactions to phoenixed company
  • legitimate businesses start transferring to new company account
  • sole director/ shareholder
  • multiple companies, similar names/ services
  • voluntary liquidation
  • links to deregistered companies

About Fintel Alliance

Fintel Alliance is an AUSTRAC-led initiative for government and industry to collaborate in the fight against serious financial crime.  

Our current priorities include disrupting organised criminal enterprises, supporting national operations, developing innovative solutions to fight serious financial crime, and protecting our community from criminal exploitation. Learn more about the Fintel Alliance