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The following indicators may assist to identify potential money laundering activity. Although the existence of a single indicator does not necessarily indicate illicit activity, it should encourage further monitoring and examination. In most cases it is the existence of multiple indicators which raises suspicion of potential criminal activity.

  • A PEP holds a mortgage or loan account and makes high-value payments into the account
  • A PEP uses the bank accounts of dependants living in another country to move funds
  • A PEP has significant holdings in bank term deposits and other high-wealth products such as shares and investment portfolios in another country
  • A PEP’s account shows high-volume account activity involving significant cash transactions
  • A PEP conducts transactions through a professional facilitator for no apparent commercial or other reason
  • A PEP is associated with, or undertakes transactions involving, large unexplained amounts of money
  • A PEP is unable or reluctant to provide details or credible explanations for establishing a business relationship, opening an account or conducting transactions
  • A PEP receives large international funds transfers to a gaming account. The PEP withdraws a small amount for gaming purposes and withdraws the balance using cheques
  • A PEP receives multiple cash deposits into their bank account from third parties within a short time frame. The cash deposits may consist of foreign currency
  • A PEP receives multiple international funds transfers from different beneficiaries within a short time frame or on the same day
  • A PEP uses legal entity structures to undertake transactions for no apparent commercial or other reason
  • A PEP uses multiple bank accounts for no apparent commercial or other reason
  • A PEP uses third parties to exchange cash for gaming chips with minimal gaming activity
  • A PEP uses a trust fund as a vehicle to move money
  • Cash deposits made in Australia by a PEP or an associate of a PEP, followed by funds withdrawals from the account, conducted in high-risk jurisdictions
  • International funds transfers where a PEP is both the ordering and beneficiary customer
  • Large cash withdrawals from a foreign PEP’s Australia-based bank account, where the account has been funded by IFTIs sent from a high-risk jurisdictions
  • Large incoming IFTIs inconsistent with the PEP’s profile
  • Large withdrawals using bank cheques, made payable to the PEP or a third party
  • PEPs from countries with poor governance
  • Personal and business transactions are difficult to distinguish
  • Ownership of property is the PEP’s only link to Australia
  • Use of corporate vehicles to obscure ownership.
Last modified: 08/07/2015 11:16