This is the short version of everything on this site, arranged for the wall rather than the screen. Print it, fill in the last section with your own business details, and keep it where the phone is.
1 · The question, and the instruction
The question: am I, right now, assisting a client to buy, sell or transfer property, or receiving and holding their money as part of that? If so, the framework is in play — whatever your job title says.
Whether your particular business is captured, and which of its activities are caught, is a matter for AUSTRAC’s guidance or your own adviser. The question above is the one to carry around; the determination is not yours or ours to make.
The instruction: it is not your job to decide whether something is suspicious enough to report. It is your job to notice and escalate.
2 · The words
| Term | Stands for | In plain English |
|---|---|---|
| AML/CTF | Anti-Money Laundering / Counter-Terrorism Financing | The framework that stops criminals using ordinary businesses to hide money or fund terrorism. |
| AUSTRAC | Australian Transaction Reports and Analysis Centre | Australia’s financial intelligence agency, and your regulator. |
| CDD | Customer Due Diligence | Working out who your client is, and recording how you know. |
| EDD | Enhanced Due Diligence | Deeper checks for clients assessed as higher risk. |
| KYC | Know Your Customer | The everyday name for the same practice. |
| ML/TF | Money Laundering / Terrorism Financing | The two risks your risk assessment has to address. |
| UBO | Ultimate Beneficial Owner | The actual human behind a company or trust. |
| PEP | Politically Exposed Person | Someone in a prominent public position, plus close family and associates. |
| PDD | Personnel Due Diligence | Checks on your own people who hold AML/CTF responsibilities. |
| SMR | Suspicious Matter Report | What the business files with AUSTRAC when something does not add up. |
| TTR | Threshold Transaction Report | A report triggered by a large cash transaction. No suspicion needed. |
| CBMR | Cross-Border Movement Report | For physical currency or bearer instruments crossing the border. |
| UAR | Unusual Activity Report | Your internal escalation. Whether it becomes an SMR is the officer’s call. |
| goAML | AUSTRAC’s reporting portal | Where the business enrols and lodges its reports. |
Thresholds, deadlines and retention periods are deliberately not on this sheet. They change, and a printed page outlives the guidance it was copied from — read those from AUSTRAC’s current guidance.
3 · What to be alert to
| Family | What it looks like |
|---|---|
| Unusual instructions or pressure | Urgency with no reason. Last-minute changes to financing or to the parties. No clear commercial purpose. |
| Avoiding normal contact | Reluctance at ID checks. Avoids meeting in person. Instructions only by messaging app, or from an unverified address. |
| Third parties who do not add up | Someone else directing while the client denies a connection. A party appearing on title who has never been in contact. Ownership changed just before settlement. |
| Funds from somewhere unexpected | Money arriving from a third party, from several accounts, or from an overseas source with no explanation. Source of funds vague or refused. |
| Trust account used as a waypoint | Funds deposited then redirected elsewhere. More paid in than the matter requires. A request to refund to a different account or party. |
| Matters that unwind | A transaction cancelled after funds have moved. Repeated near-completions that fall over late. |
| Structures without a purpose | A purchasing entity with no trading activity. A nominee or offshore party with no commercial reason to be involved. |
Every one of these has an innocent explanation, and usually that is the right one. Two or three together, or a feeling you cannot articulate — escalate. Check AUSTRAC’s current guidance for your sector rather than treating this list as complete.
4 · Escalating
| Do | Do not |
|---|---|
| Record the facts you observed — who, what, when, what was actually said. | Investigate it yourself or question the client to find out more. |
| Raise it on the client record, through your business’s own process. | Tell the client, or anyone who does not need to know, that a report has been made or considered. |
| Do it the same day, while the detail is accurate. | Decide privately that it is probably nothing. |
| Carry on with the matter professionally and normally. | Change how warm you are. That is its own signal. |
Write what you saw, not what you concluded. "Declined to meet in person three times and asked whether funds could come from two accounts" can be assessed. "Seemed dodgy" cannot.
5 · If a client asks why it is taking longer
"We need to complete some standard checks before we can proceed. They apply to every matter — I will let you know the moment we can move."
Use it for everybody, not only the files you are worried about. Checks that apply to everyone are not information about anyone — and a careful answer given only sometimes communicates the very thing you are avoiding saying.
Telling someone that a report has been made or is being considered is a criminal offence. If you think you may have said too much, tell your compliance officer straight away rather than trying to repair it yourself. Where the line falls in any particular case is a legal question for AUSTRAC’s guidance or your own adviser.
6 · Your business
Fill this in before you pin it up.
- AML/CTF compliance officer
- Phone / email
- Backup contact if they are unavailable
- Where escalations are raised
A process nobody can find is not a process. If the only person who knows how to escalate is on leave this fortnight, fill in the third line before you do anything else.
The AML/CTF acronym cheatsheet →The single-page version, if the full guide is more than you need.curlewcomply.au · Curlew Comply is a software tool and does not provide AML/CTF advice. Check thresholds and timeframes against AUSTRAC’s current guidance.