to educate Australian businesses about their money laundering and terrorism financing risks, and assist them to recognise and guard against these risks in the futureThe report is the latest of a series of studies. It features -
31 real-life case studies illustrating how Australian businesses have been misused by criminals to commit a range of serious offences, including drug importation and trafficking, identity fraud, and money laundering.Scholars might be just a tad quizzical about some of the report's authorities (eg "'Terror cash claims', The Sunday Telegraph, 2 August 2009, p.7 and 'A Sydney driver, a flash car and the $1.5m found in a Mercedes Benz in Cabramatta', The Daily Telegraph, 20 November 2009) but perhaps the specialists at Austrac are saving the meaty research for the grown-ups. The depth of analysis in the published report is underwhelming, as are insights such as use of e-gold and other virtual mechanisms by bad people.
The report provides a shopping list of 'Indicators of potential money laundering/terrorism financing activity', commmenting that -
There are numerous indicators which may act as 'red flags' for reporting entities to identify potential money laundering or terrorism financing activity.What do the flags look like? They include -
Although a single indicator does not necessarily indicate illicit activity, the existence of a 'red flag' indicator should encourage further monitoring and examination. In most cases it is the existence of multiple indicators that raises a reporting entity's suspicion of potential criminal activity, and influences their response to the situation. ...
Money launderers and terrorism financiers will continuously look for new techniques to obscure the origins of illicit funds and lend their activities an appearance of legitimacy. AML/CTF officers should continually review their products, services and individual customers to ensure their internal AML/CTF systems and training are effective.
* business undertaking transactions that appear to be inconsistent with its profile and/or transaction historyThe report has been promoted as revealing "criminal minds behind exploitation of businesses" -
* cash deposits made to an account in one location, only for the funds to be withdrawn in a different location a short time later
* cash payments for international funds transfers
* cash withdrawals conducted at various bank branches on the same day
* co-mingling of illicit funds with legitimate sources of income
* common addresses provided for funds transfers conducted by different people
* consecutive cash withdrawals below AUD10,000
* customer refuses to complete the documentation required to complete the transaction
* customer undertaking transactions that appear to be inconsistent with their profile and/or transaction history
* increase in gambling activity
* international funds transfers to a country/jurisdiction of interest to authorities (e.g. a high-risk drug/fraud jurisdiction)
* large cash deposits and/or withdrawals
* large casino chip buy-ins/cash-outs
* large international funds transfers
* large withdrawal using a bank cheque
* multiple ATM withdrawals
* multiple cash deposits and/or withdrawals
* multiple cash deposits and withdrawals below AUD10,000
* multiple cash deposits at different banks/into different accounts
* multiple cash deposits at different banks, rapidly followed by outgoing international funds transfers
* multiple cashing of cheques
* multiple customers conducting international funds transfers to the same overseas beneficiary
* multiple deposits and/or funds transfers below AUD10,000
* multiple high-value international funds transfers
* multiple low-value international funds transfers
* multiple overseas customers transferring funds into the same Australian account
* multiple purchases of bank cheques or purchase of multiple travellers cheques
* multiple visits to currency exchange businesses to purchase travellers cheques
* outgoing international funds transfer with corresponding incoming funds transfer - appears to be a u-turn transaction*
* purchase of a bank draft with bank cheque
* purchase of high-value assets (jewellery, motor vehicles, real estate)
* purchase of high-value assets with cash and company cheques
* purchasing gaming chips for a third party
* same day transactions conducted at different bank branches
* significant deposits into personal account from an apparently unrelated company
* structuring of cash deposits
* structuring transactions to avoid reporting requirements
* third party cash deposits into several different accounts (with varying amounts) conducted on the same day
* transactions conducted in various geographical locations
* unusual customer behaviour at a casino
* use of front companies
* use of trust accounts to conduct international funds transfers
* use of cash couriers
* use of cheque cashing service to cash business cheques
* use of false documentation/identification and invoices
* use of international remitter, overseas bank accounts, third parties to carry cash or conduct funds transfers/transactions
This report shows that by fulfilling reporting requirements and keeping an eye out for suspicious financial transactions, businesses can help disrupt and stop serious crimes. ...
The report includes case studies showing how:
* a $450 million ecstasy shipment was intercepted
* transaction reports submitted to AUSTRAC helped expose an Australian who was laundering the proceeds of child pornography
* a pharmacy linked to a motorcycle drug gang received cash deposits worth $1.1 million in just 15 months
* after falling in with Nigerian fraudsters, an Australian admitted to carrying a suitcase stuffed with cash overseas to be laundered
* AUSTRAC information helped track transactions of individuals suspected of being involved in the theft of $714,000 from Sydney ATM machines ...
"Every transaction tells a story and when suspicious financial behaviour is reported to AUSTRAC it can work with law enforcement agencies to detect serious crimes, including terrorism, drug trafficking, people smuggling, tax evasion, sexual abuse and theft."
