Chapter 9 - AML/CTF Reforms
We have created suspicious activity indicators to help you identify potential money laundering, terrorism financing and other serious criminal activities. These indicators can inform your transaction monitoring alerts that trigger further review.
If you suspect a customer or a transaction involving your customer is linked to a crime, submit a suspicious matter report (SMR) to AUSTRAC within the required timeframes. This includes where you reasonably suspect a person:
is committing a crime
is not who they claim to be
could be the victim of a crime.
On their own, one of these indicators may not suggest suspicious activity. If you are unsure whether there are reasonable grounds for a suspicion, you should conduct further monitoring and examination, including applying enhanced customer due diligence (ECDD) measures. If you have clear and reasonable grounds for a suspicion, you must submit a suspicious matter report (SMR) to AUSTRAC.
Customer identification and behaviour
Customer identification indicators
A customer:
provides identification information that is false, misleading, vague, or cannot be verified
has identification information that differs from the identification information listed for a payment
is identified as linked to a known crime organisation
has sources of funds or sources of wealth that are inconsistent with their profile
is unable to provide a reasonable explanation for their source of wealth or funds
attempts to provide a post office box for their residential address details
Customer behaviour indicators:
A customer:
makes an unusual enquiry to staff about whether they report to government authorities. For example, AUSTRAC, the Australian Taxation Office or law enforcement agencies
and/or their activity is the subject of law enforcement enquiries
appears nervous, overly defensive, or evasive when questioned
appears coached or rehearsed when answering questions
Money laundering
A customer:
makes unusually large and/or regular large contributions into a superannuation fund followed by rollovers of funds into a separate superannuation fund or self-managed superannuation fund (SMSF)
makes unusually large and/or regular contributions that do not match their financial profile
breaks up a large contribution into multiple smaller contributions below the $10,000 reporting threshold (this is known as ‘structuring’)
establishes a superannuation account and consolidates balances from multiple funds, and then immediately transfers or withdraws the full amount
is linked to adverse media
Fraud and tax crimes
A customer:
accesses their superannuation early, withdraws the maximum amount allowed and then rolls over the remaining balance into a new superannuation fund
whose account has unusual account activity or unauthorised requests by the member’s close relatives
provides documents from Commonwealth agencies in support of financial hardship claims that appear to be fraudulent or tampered with
provides fraudulent or altered identification documents in an attempt to gain early access to superannuation
makes fraudulent attempts to nominate someone as a beneficiary of a death benefit to illegally gain access to superannuation
provides fraudulent or altered medical certificates in an attempt to gain access to an insurance benefit under a superannuation fund
submits numerous fraudulent financial hardship claims for early withdrawal of their superannuation funds
Other indicators:
Third parties access a customer’s superannuation accounts to change contact and payment details
A customer or third party creates a SMSF account to be used for the purpose of receiving fraudulently accessed benefits
A third party impersonates a legitimate employer to access a customer’s superannuation details
Multiple customers use the same document certifier to certify fake documents for different customers, suggesting their involvement in a scheme