CC-101 · Lesson 5 · Tipping off

The one rule where "I was only being helpful" is no defence

Almost nobody tips off deliberately. It happens because a good agent wants to keep a client informed — which is exactly why it needs to be a reflex rather than a judgement call.

23 September 2026 · Amanda Dunn · 4 min read

Most AML/CTF obligations are administrative. This one is criminal, and it is the one most likely to be broken by someone with entirely good intentions.

Tipping off, broadly, is letting someone know that a report about them has been made or is being considered. The detail of the offence and its penalties belong in the Act and in advice from your own lawyer. What follows is the practical discipline that keeps you well clear of it.

Why decent people do it

Picture it. You have raised a concern internally. The settlement is slower than usual. Your client — who you like, who has done nothing obviously wrong — rings and asks what the hold-up is.

Every professional instinct you have says: explain. Be transparent. Do not leave them in the dark.

That instinct is the risk. It is not the dishonest agent who tips off. It is the conscientious one, trying to give a straight answer to a fair question.

The line to hold

Say nothing about the report, to anyone who does not need to know. Not the customer, not their solicitor, not a colleague over coffee, not your partner at home. Not afterwards, either — the obligation does not expire when the transaction does.

And do not investigate it yourself, or go looking for reassurance by asking the customer probing questions. Beyond the risk of tipping off, you are not the investigator and the interest is not served by you becoming one.

What to say instead

You need one sentence, ready, that is true and says nothing:

"We need to complete some standard checks before we can proceed."
If pressed: "They apply to every transaction — I will let you know as soon as we are able to move."
Then carry on normally. A sudden change in how warm you are is its own kind of signal.

It is true, it is unremarkable, and it is the same thing you would say to anybody. That last part matters.

If you think you may have said too much

Tell your compliance officer straight away. Do not attempt to repair it with the customer and do not sit on it hoping it was fine. Early is recoverable; discovered later is a different conversation.

Where the line falls in any particular situation is a legal question. If you are unsure, that is a matter for AUSTRAC’s guidance or your own adviser — not for a software company, and not for a blog.

What to say when a customer asks why it is taking so long →The script, and why having one ready is most of the answer.

Where Curlew fits

Keeping the conversation inside a system rather than in email is part of the protection. Curlew holds the flag and the enhanced due diligence on the customer record, visible to the people with the roles to see it, with an audit trail of who did what and when.

Fewer forwarded threads, fewer people who never needed to know, and a record of the handling that does not depend on anyone remembering who was told.