What raises risk

The customer runs a business that takes much of its income in cash (for example hospitality, takeaway food, convenience stores, car washes, beauty services or cash-based trades). Cash takings can be used to mix the proceeds of crime with legitimate income: understand the business's expected turnover and check the source of funds against it.

Wealth far greater than the client's known legal income or assets, with no reasonable explanation offered for its source — a strong, commonly-prosecuted money-laundering indicator.

Layered companies or trusts, nominee arrangements or overseas entities between the client and the people who ultimately own or control it, making the beneficial owners hard to identify and verify.

Adverse media an officer judged to be about this person or company, and a concern: weigh it in the rating and apply enhanced due diligence.

Several of the customer's answers can't both be true (income against salary, source of funds against its description, a PEP declaration against its category, payments against what was declared). Resolve each with the customer: correct the wrong answer, or record the explanation in the risk note.

Holds, or has held, a senior role in a foreign government (including family members and close associates) — frequently travels outside their jurisdiction to avoid domestic law enforcement and move funds offshore.

An individual may be involved in crime and use criminal proceeds through the designated service — money laundering, terrorism financing, fraud, tax evasion, corruption, drug trafficking, people smuggling and similar offences.

A highly complex or unusual ownership and control structure that's difficult to analyse layer by layer — not effectively anonymous if reliable documents (e.g. a trust deed) show the individuals with ownership or control.

The same person, bank account or property appears on another of the firm's cases, and the officer who reviewed it decided the link is a concern (for example the other case was declined, investigated or reported, or the person acts for several unrelated customers).

Someone who owns or controls the customer, directly or through other companies or trusts, has been confirmed as a match on a sanctions list. Dealing with the customer is dealing with their assets: the service can't go ahead.

Sanctions screening found a listing that may be this person or company, and it has not been ruled out as someone else. If it is them, the service can't go ahead: freeze any assets held, report to the Australian Sanctions Office (DFAT) and the AFP, and consider a suspicious matter report.

A suspicious matter report has been drafted or lodged about this customer. If the firm keeps providing the service, apply enhanced customer due diligence and monitor the relationship closely, without telling the customer about the report.

Registered charities and legitimate NPOs are an attractive channel for terrorism financing — donations solicited from many individuals, witting and unwitting, then diverted for illicit purposes.

The client is a minor. A minor cannot normally give binding instructions or enter a binding contract, so a parent, guardian, trustee or estate administrator should be acting with evidenced authority. Using a family member or other third party can distance the real owner from illicit funds — establish who controls the matter and who provides or receives the money.

Holds, or has held, a senior role in an Australian government body (including family members and close associates) — public profile, vulnerable to corruption and bribery over spending, procurement and approvals.

Holds, or has held, a senior role in an international organisation (including family members and close associates).

Harder to independently verify identity and source of funds at a distance; residence in a FATF-listed high-risk country is rated separately, not folded into this one.

The customer, an owner or a representative says they (or a family member or close associate) are a politically exposed person. Confirm the category: a foreign PEP is high risk and needs enhanced due diligence and senior management approval; a domestic or international-organisation PEP is rated on the other risks.

An individual acts through a third party or intermediary rather than directly — doesn't apply where the third party is itself an AUSTRAC-enrolled reporting entity.

The customer acts through a company, trust or other legal arrangement. On its own this is common and rated medium; a complex or opaque ownership or control structure is rated separately, as high.

Unregulated private lending, or a lender based overseas: the "loan-back" AUSTRAC describes, where an offshore company controlled by the buyer poses as an arm's-length lender. Escalate to the compliance officer, verify the lender's identity and source of wealth, review the loan and mortgage documents, and trace the funds to the lender.

Funds pooled from investors, often through a legal trust account, which hides who is providing them. Review the loan agreement, identify the investors or the trust behind it, and trace the money to where it came from.

Money paid in by someone who isn't on the case, from an account the customer didn't declare, or pooled from several payers. The patterns of offsetting and underground banking, where the money that arrives isn't the money the customer moved. Find out who each payer is, how they're connected, and where their money came from.

A payment refunded to someone other than the payer, to a different account, as a transfer for cash paid in, before due diligence was finished, after a deal ended with no clear reason, or handed back as an overpayment. A deposit paid and taken back is a known way to turn dirty money into a clean transfer from a trust account. Confirm who the money belongs to and why it went where it did, and consider whether an SMR is needed.

Any transaction involving a virtual asset unusual for the circumstances — near-instant, low visibility of who actually controls the funds, bypasses financial-institution oversight once cashed out of fiat.

Non-bank lenders and private credit funds are reporting entities AUSTRAC rates medium risk as a sector, and see less of where a borrower's wealth comes from than a bank. Confirm the lender is enrolled with AUSTRAC and did its own due diligence, and review the loan and mortgage documents.

Money paid in from, or wealth said to come from, a country that limits what its residents may send abroad. Not suspicious on its own: ask how the funds left the country and for evidence (remittance records, approvals). Where the country doesn't let its residents send money abroad to buy property, a property purchase funded from there needs a clear answer.

The customer is dealt with wholly remotely. Rated by how their identity was verified: an automated check with a selfie and liveness test is medium; a document checked by staff, or a customer living overseas, is high.

Fake identification documents, false details, or technology used to impersonate someone else — spoofed phone numbers/emails and deepfake images/video make this easier across every remote channel (email, phone, video conferencing, online platforms).

The identity verification was done from a different country than the one the customer lives in, or through a VPN, proxy, Tor or a data centre, which hides where they are. Travelling is the usual explanation: ask, and accept it when it checks out. Unexplained, it can mean someone else is acting for the customer, or that they are overseas.

The customer is dealt with through someone else (an agent, adviser or other intermediary), so the firm never deals with them directly. Confirm the intermediary's authority to act and that the instructions are the customer's own.

The party is resident in a country on FATF's list of jurisdictions with strategic AML/CTF deficiencies — either the black list (call for action) or the grey list (increased monitoring). Either listing raises this factor; which one applies is shown alongside the result so a compliance officer can weigh it.