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.
To complement these indicators, you must also ensure your transaction monitoring systems alert you to unusual, large or complex transactions or patterns of transactions.
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.
For more information on complying with your reporting obligations, see our suspicious matter reporting reference guide and suspicious matter reporting checklist.
This indicators list is not exhaustive. You should consider other indicators specific to your business’s individual risk profile and circumstances.
On this page
Customer identification and behaviour
Customer identification indicators
A customer:
- provides identification information that is false, misleading, vague, or cannot be verified
- refuses and/or is reluctant to provide identification information or documents
- is identified in adverse media
- provides a billing or delivery address which is in a different region or country from their residential address
- has sources of wealth or sources of funds that is unexplained and/or inconsistent with their profile (for example: students and government payment recipients)
- uses a post office box or private service provider’s address, instead of providing a residential address
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
- enquires about transaction limits or requests their transaction not be reported
- and/or their activity is the subject of law enforcement enquiries
- appears nervous, overly defensive, or evasive when questioned
- requests to be anonymous
- refuses to provide details about why they are buying bullion
- asks questions about reporting and identification thresholds or requests advice on how to avoid them
- appears to be directed by a third party. For example, the customer refers to information by or is accompanied by another person, or appears coached or rehearsed when answering questions
- is uninterested in the details of the purchase, such as the price, transaction fees, delivery cost or storage fees
- refuses to provide identification documents
- has a third party collect the bullion on their behalf
Money laundering
Money laundering indicators
A customer:
- buys and sells bullion frequently at a loss
- purchases high value bullion or paying invoices using large sums of cash
- breaks down transactions into smaller amounts to avoid the $5,000 customer identification threshold or the $10,000 transaction reporting threshold. For example, smaller payments over consecutive days or across multiple branches.
- attempts to over or under-value the purity and/or weight of the bullion, misclassify the metal, misrepresent the price, quantity or quality of the bullion or disguises its origin
- chooses a payment method (such as a credit card) that incurs fees rather than an alternative method that does not incur fees
- divides payments for bullion into electronic transfers, cheques, smaller cash transactions or cash deposits.
- makes frequent payment deposits via methods where it is difficult to determine the source of funds e.g. e-wallets, cryptocurrencies, EFTPOS gift cards etc.
- splits bullion purchases with another person to reduce the visibility of the transaction
- purchases multi-kilo amounts of bullion over an unusually short period
- makes multiple bullion purchases over a short timeframe
- has an account which is paid by a third party
- requests bullion to be shipped to jurisdictions designated as ‘high-risk’ for money laundering or terrorist financing activities
- makes multiple transactions over a short timeframe involving foreign nationals
- states the bullion is to be taken overseas after it is purchased
- who is not within the bullion or jewellery industry has a number of companies registered to them or recurrently uses business accounts to pay for bullion
- who is a non-permanent resident of Australia purchases bullion in amounts they can conveniently and discreetly transport overseas
Other indicators:
- individual bullion dealers are linked to known or suspected criminals and/or criminal groups
- a jewellery business purchases bullion in quantities exceeding what you consider normal for a business of their size, and may pay invoices using cash
- a jewellery business frequently sells jewellery to your business and then uses the profits to purchase bullion
Terrorism financing
Terrorism financing indicators
- A customer is matched through screening against an Australian or international sanctions list.
- Open source information identifies a customer has links to known terrorist organisations or terrorism activities
- Open source information indicates a customer displays extremist ideologies (for example, social, political or environmental)
Related pages
The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.