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
- Money laundering
- Fraud and counterfeit notes
- Terrorism financing
- Related pages
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 ID, and asks staff to refer to information or ID previously provided/on-file
- advises they have no ID and requests winnings be paid in cash to the threshold amount, but 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
- has sources of wealth and sources of funds which indicate they are linked to a business in an industry known for being cash-intensive. Therefore, electronic gaming machine (EGM) play or cashing out for a cheque or electronic funds transfer (EFT) payment may indicate they are putting the business’ gross takings through EGMs to avoid paying tax, or to lower their tax liability
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
- attempts to influence a new staff member to ignore their suspicious activity, including by offering tips
- plays EGMs at a venue far from the home address listed on their ID or their known place of business
- 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 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
- shares funds with another patron they have no apparent relationship with
Money laundering
Money laundering indicators
A customer:
- tries to circumvent note insertion limits by playing multiple EGMs at once, sometimes non-adjacent EGMs
- abandons an EGM and fails to request a payout once credits are to a value greater than the cheque or EFT payment threshold amount
- approaches another customer at an EGM and offers to purchase their ticket in ticket out (TITO) ticket or the credit on their EGM
- photographs their TITO ticket so they can later rely on it to justify receipt of funds
- plays an EGM then saves cash redemption terminal (CRT) receipts so they can later rely on them 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)
- feeds cash into an EGM and requests a cheque or EFT payment after minimal or no play
- 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
- repeatedly collects winnings just below the thresholds for mandatory ID collection
- has large sums of cash, with indications they have recently been involved in a serious crime (for example, wearing an electronic tracking device)
- 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
- retains winning cheque/s without redemption or depositing for an extended period (e.g. weeks, months or years)
- and/or third-parties closely watch patrons with high winning tickets and offer to exchange their winning tickets with cash and extra incentives
- presents high volume cheque payouts
Other indicators:
- Individual EGM hoppers have large sums of cash inserted but records indicate minimal or no play
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
Open source information:
- indicates customer is a member of, or linked to, a known terrorist organisation or terrorism activities
- indicates a customer displays extremist ideologies (social, political, environmental etc.).
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.