What commingling means
In money laundering, commingling means mixing criminal proceeds with lawful money. A business can be used to present that mixed value as ordinary receipts. AUSTRAC’s 2024 risk assessment identifies this risk in cash-intensive businesses.
Cash-intensive means that cash forms a substantial part of the business’s receipts or activity. Accepting cash is not itself an offence or evidence of commingling.
Source: AUSTRAC: Printed pages 44 and 46 to 47: cash-intensive businesses and co-mingling.
Compare the explanation with the records
A useful review asks whether receipts fit the stated business activity. Consider the available sales records and the customer’s explanation. A difference may need clarification. It does not by itself prove the source was criminal.
Keep the review tied to the service and applicable duties. Do not impose an unsupported claim about every customer in an industry.
Source: AUSTRAC: Printed pages 44 and 46 to 47: cash-intensive businesses and co-mingling.
Example: receipts without supporting sales
A fictional business attributes increased cash receipts to a new product. The records supplied do not identify sales of that product. The reviewer records the gap and asks for supporting information through the approved process.
The explanation may be supported by further records. If the concern remains, the reviewer follows the escalation procedure. They do not invent a predicate offence to explain missing information.
Source: AUSTRAC: Printed pages 44 and 46 to 47: cash-intensive businesses and co-mingling.
- Customer explanation
The business attributes increased cash receipts to a new product.
- Supporting records
Examine whether records support sales of that product.
- Review result
Record supported facts and any unresolved gap.
Compare the claimed receipts with the evidence
Illustrative review of the fictional sales example. A gap needs assessment and does not itself prove commingling.
Separate evidence questions. An answer to one does not settle the others.
Separate product use from wrongdoing
Ordinary business accounts and cash services can support lawful activity. The question is how they are used in the particular relationship. Record the facts, explanation and reason for the next action. Use the source-of-funds article for the evidence question.
Source: AUSTRAC: Printed pages 44 and 46 to 47: cash-intensive businesses and co-mingling.