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
  • is reluctant to provide identification information or documents, or asks staff to refer to information or ID previously provided or on-file
  • advises they have no ID and requests winnings be paid in cash to the threshold amount, and never returns to collect the balance
  • is identified in adverse media 
  • has sources of wealth or sources of funds that are unexplained and/or inconsistent with their profile

Customer behaviour indicators

A customer:

  • attempts to influence staff members to ignore their activity, including offering tips and/or other incentives
  • frequently deals with only one staff member and avoids other staff
  • makes an unusual enquiry to venue 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
  • who regularly uses a loyalty card suddenly doesn’t use it and appears to have significant winnings
  • and/or their gaming activity is the subject of law enforcement enquiries
  • mentions they have been banned from playing electronic gaming machines (EGMs) at another venue, where the reason does not appear to be related to problem gambling
  • appears nervous, overly defensive, or evasive when questioned
  • appears coached or rehearsed when answering questions

Customers:

  • with no known or apparent relationship share funds
  • collude in gaming activities, including gambling on both likely outcomes of certain games (for example one betting on red and the other betting on black in roulette)

Money laundering

Money laundering indicators

A customer:

  • approaches another customer at an EGM and offers to purchase the credit on their EGM
  • abandons an EGM and fails to request a payout once credits are to a value greater than the cheque or EFT payment threshold amount
  • tries to circumvent note insertion limits by playing multiple EGMs at once, sometimes non-adjacent EGMs
  • feeds cash into an EGM and requests a cheque or electronic funds transfer (EFT) payment after minimal or no play
  • uses third parties to place cash funds into cash redemption terminals (CRTs)
  • plays an EGM then saves CRT receipts so they can later rely on them to justify receipt of funds
  • collates multiple ticket-in ticket-out (TITO) tickets and redeems them all at once, or there are significant delays in the customer redeeming TITO vouchers
  • photographs their TITO ticket so they can later rely on it to justify receipt of funds
  • requests to take a photograph of another customer’s TITO ticket so they can later rely on it to justify receipt of funds
  • requests any redeemed TITO tickets or CRT receipts from venue staff
  • retains winning TITO tickets or payout vouchers without redemption for an unusually long period (for example, weeks, months or years)
  • presents a combination of TITO tickets and cash, asking to exchange them for a cheque
  • presents multiple TITO tickets to exchange for a cheque
  • asks for multiple TITO tickets under the cheque threshold to be paid as a cheque
  • has large sums of cash, with indications they have recently been involved in a serious crime (for example, wearing an electronic tracking device)
  • repeatedly collects winnings just below the thresholds for mandatory ID collection
  • places funds into casinos through multiple purchases of chips or gaming credits with cash amounts under $10,000 (known as structuring), followed by cashing out with minimal or no play
  • makes multiple chip cash-outs on the same day
  • uses third parties to gamble proceeds through casinos
  • uses third parties to purchase gaming chips
  • and/or third-parties closely watch patrons with high winning tickets and offer to exchange their winning tickets with cash and extra incentives 
  • whose known or /declared occupation is in a cash-intensive industry, gambles with large amounts of cash
  • exchanges small denomination notes for large denomination notes at the casino’s cage
  • makes frequent transfers in and out of the casino using the casino’s financial services
  • attempts to disguise illicit funds through falsely claiming winnings or purchasing winning tickets or jackpots in cash from other customers   
  • has large amounts of cash from unexplained sources and/or inconsistent with their profile
  • frequently plays games with low returns but higher chances of winning
  • who is identified as a politically exposed person (PEP), or as being linked to one: 
    • conducts large cash transactions;
    • undertakes rapid movement of funds; or
    • is evasive of about their source of funds or source of wealth
  • repeatedly collects winnings just below the customer identification threshold
  • uses other customer’s loyalty or membership card
  • attempts to have funds directed to a third party
  • supplies a third-party’s BSB and account number, along with their own account name, to effect a payment to a third-party without detection
  • states they don’t have a bank account and insists on receiving cash
  • offers venue staff a small gift or bribe to not record any details of a cheque or EFT payment
  • advises venue staff they have a ‘cash business’ and asks to exchange cash for cheques
  • presents high volume cheque payouts

Other indicators:

  • Multiple individuals or customers aggregate or pool deposits in a casino’s bank account, followed by a single transfer to a single customer’s casino account

Money mule indicators

A customer:

  • is a student and non-permanent resident, or is a student and has an international passport and/or proof of age card
  • is a director or secretary of a recently incorporated company
  • has access to more cash or wealth than would be expected for their profile 
  • conducts exchanges of cash and physical chips among other patrons 
  • exchanges small denomination notes for larger denominations 
  • exchanges foreign currency to and/or from Australian currency with no gaming play 
  • requests cheque payment for or non-winnings 

Fraud and counterfeit notes

Fraud indicators

A customer:

  • sells a cheque issued by a venue to a broker and then returns to the venue advising they have lost the cheque and require a replacement
  • alters the name of the payee of a cheque or changes the dollar amount to a higher value

Counterfeit note indicators

A customer:

  • attempts to use counterfeit notes to credit an EGM
  • presents a banknote that is rejected by an EGM or CRT as the note is identified as being counterfeit
  • asks the cashier to change banknote denominations instead of using a CRT with a counterfeit note scanner
  • asks to change banknote denominations for odd reasons (for example, because they are a collector seeking a specific note serial number or series)

Terrorism financing

Terrorism financing indicators

A customer:

  • is matched through screening against an Australian or international sanctions list 
  • sends or receives funds to or from higher-risk jurisdictions for terrorism or terrorism financing
  • enquires about transferring funds to or from higher-risk jurisdictions for terrorism or terrorism financing

Open source information:

  • indicates customer is linked to a known terrorist organisation, or terrorist activities 
  • indicates a customer displays extremist ideologies (social, political, environmental etc.).

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.

Last updated: 30 Sep 2024
Page ID: 1109

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