An alert starts a review
An AML alert identifies activity that needs examination. The reviewer compares the facts with customer information and the relevant legal duties.
Internal escalation means sending a matter to a person with authority to decide or act. It does not mean that AUSTRAC has received a report.
Source: AUSTRAC: Responding to unusual transactions and behaviour; Step 1; Step 3.
Record the facts and the gap
A useful review identifies the customer, service, activity and time. It separates staff observations, the customer’s account and the reviewer’s conclusions.
Existing records may resolve the concern. If a material gap remains, identify the evidence needed and who will obtain it.
Possible responses include further review, a customer risk update or enhanced CDD. The actual response depends on the facts and applicable conditions.
Source: AUSTRAC: Step 1; Step 2; Step 3.
Make the handover usable
A suggested handover states the concern, evidence, unresolved question and required decision. Name the receiving person and confirm that they received the matter.
Record the actual time a suspicion forms. An internal meeting or queue does not restart a reporting deadline.
The SMR article gives the reporting test and deadlines. Customer contact also needs care under the tipping-off rules.
Sources: AUSTRAC: Step 3; Step 4; AUSTRAC: Submission deadlines; AUSTRAC: What is tipping off.
- Facts
Record the customer, service, activity and unresolved question.
- Handover
Send the evidence to a person with authority and confirm receipt.
- Decision
Record the response, reasons and any required report.
Give the next person a usable decision record
Internal escalation is not an AUSTRAC report. A queue or meeting does not restart the legal reporting deadline.
Follow the process from top to bottom.
A concern before staff leave
A fictional reviewer finds conflicting ownership instructions near the end of a shift. The usual decision maker is absent.
The reviewer sends the evidence and open question to the nominated backup. The backup records the decision and any further action.
If suspicion has already formed, the report follows its legal deadline. If the evidence resolves the concern, the record states why no further action is needed.
The file retains the review steps, response and reasons. Closing the alert is a recorded decision, not proof that the customer presents no future risk.
Sources: AUSTRAC: Step 4; Record keeping; AUSTRAC: Submission deadlines.