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 tax crimes
- 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
- has identification information that differs from the identification information listed for a payment
- is identified as linked to a known crime organisation
- has sources of funds or sources of wealth that are inconsistent with their profile
- is unable to provide a reasonable explanation for their source of wealth or funds
- attempts to provide a post office box for their residential address details
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
- and/or their activity is the subject of law enforcement enquiries
- appears nervous, overly defensive, or evasive when questioned
- appears coached or rehearsed when answering questions
Money laundering
Money laundering indicators
A customer:
- makes unusually large and/or regular large contributions into a superannuation fund followed by rollovers of funds into a separate superannuation fund or self-managed superannuation fund (SMSF)
- makes unusually large and/or regular contributions that do not match their financial profile
- breaks up a large contribution into multiple smaller contributions below the $10,000 reporting threshold (this is known as ‘structuring’)
- establishes a superannuation account and consolidates balances from multiple funds, and then immediately transfers or withdraws the full amount
- is linked to adverse media
Fraud and tax crimes
Fraud indicators
A customer:
- accesses their superannuation early, withdraws the maximum amount allowed and then rolls over the remaining balance into a new superannuation fund
- whose account has unusual account activity or unauthorised requests by the member’s close relatives
- provides documents from Commonwealth agencies in support of financial hardship claims that appear to be fraudulent or tampered with
- provides fraudulent or altered identification documents in an attempt to gain early access to superannuation
- makes fraudulent attempts to nominate someone as a beneficiary of a death benefit to illegally gain access to superannuation
- provides fraudulent or altered medical certificates in an attempt to gain access to an insurance benefit under a superannuation fund
- submits numerous fraudulent financial hardship claims for early withdrawal of their superannuation funds
Other indicators:
- Third parties access a customer’s superannuation accounts to change contact and payment details
- A customer or third party creates a SMSF account to be used for the purpose of receiving fraudulently accessed benefits
- A third party impersonates a legitimate employer to access a customer’s superannuation details
- Multiple customers use the same document certifier to certify fake documents for different customers, suggesting their involvement in a scheme
Employee fraud indicators
An employee:
- accesses members' superannuation accounts without authorisation to change contact and payment details
- makes unauthorised withdrawals from members’ superannuation accounts who have reached post preservation age
Tax evasion indicators
- Customer’s account has unusual activity, such as a member making large contributions over a short period of time inconsistent with their profile
- Employer registers fake employees in an attempt to funnel pre-tax monies into employee accounts, to lower the employer’s tax liability
Terrorism financing
Terrorism financing indicators
A customer:
- attempts to access benefits under financial hardship, followed by an attempt to roll over funds into a SMSF if the request is denied, with member expressing little to no knowledge of what a SMSF is
- 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
- 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.