We have created suspicious activity indicators to help you identify potential money laundering, terrorism financing and other serious criminal activities. On their own, one of these indicators may not suggest suspicious activity. 

If you have clear and reasonable grounds to suspect a customer or a transaction involving your customer is linked to a crime, you must submit a suspicious matter report (SMR) to AUSTRAC within the required timeframe. 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.

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 an identification document that cannot be authenticated
  • provides identification information that is misleading, vague, or difficult to verify
  • provides identification documents are inconsistent with expected formats, appear altered or have inconsistencies
  • is identified in adverse media
  • is linked through screening to a known criminal organisation
  • has sources of wealth or sources of funds that are unexplained and/or inconsistent with their profile
  • refuses or is reluctant to provide identification information or documents 
  • has inconsistencies in identification information across different identification documents
  • provides a post office box for their residential address details
  • has multiple accounts (including personal accounts, joint accounts and trust accounts) without any economic rationale
  • has sources of income that are unclear or confusing
  • is a client of a bank that is intending to close their accounts (also known as ‘de-risking’ or ‘de-banking’) 
  • uses company or trust structures with unclear beneficial owners 
  • that is a self-managed superannuation fund (SMSF) has several changes in members or trustees over a short period of time 
  • changes bank details by email or online soon after changing their contact details 

Customer behaviour indicators

A customer:

  • appears nervous, overly defensive, or evasive when questioned
  • and/or their activity is the subject of law enforcement enquiries
  • 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
  • requests the financial planner to transfer funds to a conflict zone jurisdiction or a jurisdiction neighbouring a conflict zone
  • uses an agent to act on their behalf with no economic rationale
  • asks whether an exclusion period on an insurance policy can be reduced or whether a benefit can be paid to someone other than the stated beneficiary or policy owner
  • asks how long they need to pay premiums on an insurance policy before a claim can be made 
  • enquires whether the financial planner accepts large cash deposits 
  • requests advice on overly complex company or trust structures that go beyond their ­financial needs or have no economic rationale
  • requests unusual investments or investments with no economic rationale
  • asks to establish a SMSF without being able to show source of funds or ownership for the initial transfer of funds
  • expresses unusual urgency in an email request for transactions to occur 
  • requests changes to their financial investment strategy with no economic rationale

Money laundering

Money laundering indicators 

A customer:

  • approaches a financial planner with cash total in excess of their annual income from running their own business 
  • asks a financial planner to transfer very large sums of money between numerous bank accounts held by the customer, in an attempt to obscure the source of the funds
  • provides suspicious bank statements to authenticate change of bank detail requests
  • has suspicious property ownership arrangements 
  • receives a rollover to their SMSF, but does not lodge its first ever annual return
  • was investing their SMSFs into highly unusual derivatives products overseas
  • consolidates funds from several sources into their account
  • makes structured or large cash deposits into their bank account to facilitate investments 
  • quickly withdraws funds soon after making an initial investment
  • who is a foreign national uses a financial planner to invest a large sum of money that is inconsistent with the customer’s profile, and the source of the funds is unclear
  • aggregates funds from various sources into their account, including funds coming through a developing country or a higher-risk jurisdiction

Tax, welfare and cyber-enabled fraud

Tax evasion indicators

A customer:

  • requests advice on how to evade tax
  • requests advice on overly complex company or trust structures that go beyond their financial needs
  • has overly complex property ownership arrangements
  • has money in, or controls corporate entities based in jurisdictions known for being tax havens or having tax secrecy laws
  • has undeclared cash and/or foreign income, evidence of excessive tax deductions, and/or suspicious property ownership arrangements
  • located off-shore has overly complex layers of corporate and/or nominee shareholders and directors 
  • has not filed their income tax return for an extended period

Cyber-enabled fraud indicators

A customer:

  • sends an email that has different tone or language to customer’s usual communications 
  • sends an email that has unusually poor grammar, spelling mistakes or uncommon terminology 
  • contacts the financial planner by email when they usually contact them by telephone
  • changes bank details soon after changing other details such as address or phone number 
  • sends emails that express unusual urgency to facilitate transactions 
  • asks the financial planner to complete application forms on their behalf, and to then send forms back to the customer for signing
  • emails a request to send funds overseas with no economic rationale

Welfare fraud indicators

A customer:

  • makes transactions that are inconsistent with the expected profile of a customer receiving government benefits 
  • receiving government benefits has additional transactions that may indicate an additional source of income
  • does not declare additional income and any changes in circumstances to Centrelink
  • continues to claim a benefit they may not be entitled to
  • reveals they are misleading Centrelink for welfare benefits 
  • has the majority of their NDIS-sourced funds paid into loan accounts 
  • uses NDIS-sourced funds for transactions inconsistent with their profile 
  • accumulates NDIS-sourced funds over a period of time, followed by large withdrawals or expenditure on goods or services unrelated to disability support 
  • known to be running a NDIS provider business, or providing disability support services conducts transactions do not appear to correlate with this

Terrorism financing

Terrorism financing indicators

A customer:

  • has a funds transfer stopped by their originating bank (for example a transfer to the financial planner’s bank account, or a funds transfer they attempted to make) 
  • requests a large funds transfer to a higher-risk jurisdiction for terrorism financing 
  • is matched through screening against an Australian or international sanctions list
  • makes transactions that appear to have links to known terrorist entities or terrorism activities 

Open source information:

  • identifies that a customer has links to known terrorist organisations or terrorism activities 
  • indicates that a customer displays extremist ideologies (for example, social, political or environmental)

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: 1111

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