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The following indicators may assist to identify potential money laundering. 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. 

  • Cash deposited in structured amounts into home loan accounts
  • Cash deposited into an account in structured amounts, then withdrawn via transfer or bank cheque to a payee that is a real estate firm, conveyancer or legal trust account
  • Cash deposits used to make rental payments months in advance
  • Cash used to make a significant deposit for the purchase of a property and the balance is financed by an unusual source – for example, a third party, private lender or offshore bank
  • Complex transactions in which multiple properties are bought, re-sold or exchanged
  • Customer appears to be acting on behalf of another person and is reluctant to identify those they represent
  • Customer arranges for proceeds of sale of property to be transferred directly to an account in a high-risk jurisdiction (14)
  • Customer buys multiple properties in a short period of time
  • Customer buys or sells property above or below market value while apparently unconcerned about the economic outcome of the transaction
  • Customer buys property in the name of a third party, relative or minor
  • Customer deposits cash to buy a property but then pulls out from the transaction and requests a refund by cheque
  • Customer repays loan early, or is significantly in advance on their payments
  • Deposits to buy a property have been sourced from an offshore bank
  • Introduction of unknown parties at a late stage of a transaction
  • Low-value property bought with subsequent improvements paid for in large cash amounts before re-selling
  • Non-individual purchasers whose corporate or legal entity structures are complex for no apparent commercial or other reason
  • Ownership of property is the customer's only link to Australia
  • Source of deposits to buy a property cannot be easily identified – for example, international funds transfer where the ordering and beneficiary customers are the same
  • Transactions in which the parties are foreign or a non-resident for tax purposes
  • Transactions where there are doubts about the validity of the documents submitted with loan applications


  1. 'High-risk jurisdictions' are jurisdictions known to be a source of narcotics or other significant criminal activity, any jurisdiction subject to sanctions, jurisdictions known to be a secrecy haven or preferential tax regime, or jurisdictions linked to proscribed terrorist organisations.
Last modified: 02/06/2015 10:09