Read our examples of how transactions are commonly linked or appear to be linked, in practice.
The following examples show how transactions are commonly linked in your industry. Some are clear cases where transactions are linked or not linked. Others highlight situations where you need to assess whether transactions are connected based on the facts.
In determining whether transactions are linked, consider whether they:
- are connected to the same items
- are connected to the same purchase or sale
- are connected to an ongoing arrangement
- have an underlying purpose (including attempts to structure under the $10,000 threshold).
Learn more about what you are expected to consider.
Examples of linked transactions
The following examples show how transactions are commonly linked in your industry.
Example 1 – Instalment arrangement for the same item
Your customer buys an item valued at $12,000. They pay a $9,000 deposit in cash. They return the next day and pay the remaining $3,000 in cash.
These are linked transactions because both payments relate to the same sale and item.
As the combined value of these linked payments is $12,000, you’ll be regulated if you accept both these payments.
Example 2 – Layby payments for the same item
Your customer puts a $15,000 item on layby. They pay a $3,000 deposit, and multiple cash instalments totalling $12,000.
These are linked payments as they all relate to the same sale and the same item. Their combined value is $15,000, above the $10,000 threshold for regulation.
Example 3 – Invoice paid in cash instalments for the same items
You’re a supplier and you invoice goods for $12,000. Your retail customer agrees to pay in 3 cash instalments of $4,000 over 3 months.
These are linked transactions because they all relate to the same sale and the same items. Their combined value is $12,000, which is above the $10,000 threshold for regulation.
Even if payments are spread over time, they remain linked transactions. There is no time limit after which linked transactions reset for threshold purposes.
Example 5 – Return and exchange with a cash top-up for the same items
Your customer buys 2 jewellery items, one for $7,000 and one for $2,000. They pay $9,000 cash for both items.
Your customer returns 3 months later to return the $2,000 item. The customer asks to exchange it for a $7,000 item and pay the difference in $5,000 cash.
Although it wasn’t initially, this is now a linked transaction.
If you accept the difference paid in cash or virtual assets, this becomes a linked transaction. This is because:
- the exchange and cash top-up is connected to the original sale and sold items
- when assessed together, the total value of the linked transactions is at or over $10,000.
Example 6 – Payments for different items made under the same ongoing business arrangement
You’re a retail business, and you have an overseas supplier that supplies you precious metals, stones and products. Your supplier delivers jewellery items to you, on the following terms:
- you sell the items you purchase from the supplier in your retail store
- each month they will visit you and collect payment in cash for the goods sold to date.
Over time, the total cash payments exceed $10,000.
“Goods sold to date” means the cumulative value of goods supplied to you under the arrangement. It includes goods already paid for and goods that remain outstanding.
These payments are linked, and AML/CTF obligations apply to you because the:
- payments are part of a single, ongoing arrangement from with payments for precious metals, stones and products made over an extended period
- purchases are a part of carrying on a business
- payments are made in cash and are valued at or over $10,000 over time.
Example 7 – Transactions linked to the same structuring purpose
Your customer buys a $9,000 gold chain in cash from a staff member. Before leaving, they ask the staff member what their rostered days off are.
The same customer returns on a day that the staff member who sold them the chain has a day off. This time they buy an $8,000 gold chain from a different staff member in cash. The second staff member is not aware of the previous sale.
This pattern is repeated over the next two days with two other staff members The customer returns each day to purchase products both:
- in cash
- under the $10,000 threshold.
When reviewing your transaction records, you identify that:
- the same customer details are recorded for both purchases
- the transactions occurred on consecutive days
- the purchases involve similar items at similar values
- different staff members processed each sale.
You question the 4 staff members about the transactions. The first staff member tells you that the customer asked about their work roster in conversation.
This behaviour indicates deliberate structuring. The customer appears to plan transactions, so they’re processed by different staff members.
This behaviour indicates structuring, and therefore linked transactions, because the customer:
- asks about staff availability before making further purchases
- returns when the first staff member isn’t working, ensuring a different staff member processes the transaction
- uses staff members who are unaware of earlier transactions, reducing the likelihood the transactions will be linked
- makes separate cash transactions for similar purchases, over consecutive days, each below $10,000.
As the linked transactions are valued at $10,000 or more collectively, they would be regulated under the AML/CTF Act.
Examples of transactions that are not linked
These examples show situations where transactions are not linked because they are separate and not connected.
Example 1 – Discounted sale
Your customer buys an item valued at $11,000 and you offer a discount to $9,900 for a cash payment. This is a single transaction below $10,000. On its own it’s not a linked transaction.
If this pricing approach is repeated with the same customer, it may indicate structuring and should be assessed.
Example 2 – Same customer returns next day for a similar purchase
Your customer buys a $7,000 diamond pendant and gold chain for their daughter, in cash. The next day they return to buy another $7,000 gold chain for their other daughter, in cash. Each transaction is below $10,000 and there is no instalment arrangement or shared invoice.
On these facts alone, these aren’t linked transactions because they both:
- relate to separate items and sales
- don’t seem to be linked to any broader arrangement.
Example 3 – Two different customers purchasing the same kind of item
Your customer buys a $6,000 diamond ring in cash. The next day a different customer asks to buy the same kind of ring that their friend purchased. They also pay in cash.
These are 2 separate customers, with separate transactions. Based on these facts, this isn’t a linked transaction.
Even if there are more similar transactions, they’re still not linked, unless something connects them. For example, the same customer returns to purchase the same or a similar item in cash and they’re displaying unusual behaviour to avoid the $10,000 threshold.
Related pages
This guidance sets out how we interpret certain Australian legislation, 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.