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, taking part in the sale, purchase or transfer of property as part of this business? 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 customer is, and recording how you know. |
| EDD | Enhanced Due Diligence | Deeper checks for customers 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 · Seven families of red flag
| Family | What it looks like |
|---|---|
| Unusual instructions or pressure | Urgency with no reason. Last-minute financing changes. No clear commercial purpose. Buying without inspecting. |
| Avoiding normal contact | Reluctance at ID checks. Avoids meeting in person. Messaging apps only. |
| Third parties who do not add up | Someone else directing while the customer denies a connection. Purchase in another name. Ownership changed just before settlement. |
| Profile and paperwork mismatch | Wealth inconsistent with occupation. ID that cannot be authenticated. Vague or refused source of funds. |
| Money behaving strangely | Cash, especially large. Deposit held in trust then redirected. Virtual assets offered. Quick resale at an unexplained price. |
| Over or undervaluation | Price well above or below market with no logical driver. |
| Shell and offshore structures | A purchasing company with no trading activity. A secrecy-jurisdiction entity with no commercial reason. |
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. AUSTRAC publishes risks-and-indicators guidance for real estate; read it for the full picture.
4 · Escalating
| Do | Do not |
|---|---|
| Record the facts you observed — who, what, when, what was actually said. | Investigate it yourself or question the customer to find out more. |
| Raise it on the customer record, through your business’s own process. | Tell the customer, 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 customer 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.