What makes the activity professional
Professional money laundering means providing laundering services to others for a fee, commission or profit. A network can coordinate people and services for more than one criminal group. The term concerns the laundering activity. It does not mean that every person holds a professional licence.
AUSTRAC’s May 2026 update describes established networks serving organised crime groups across different financial services. This is a national risk finding, not a finding about every service provider.
Sources: AUSTRAC: Financial channels and criminal activities; FATF: Printed pages 10 to 11: Key characteristics.
Separate an adviser from a criminal role
A lawyer, accountant or company service provider can perform lawful work. Their involvement alone does not establish laundering. A review must identify the relevant instructions, activity and evidence.
Do not treat a shared adviser or registered address as proof of common criminal control. Ask what the connection actually shows and what remains unknown.
Sources: AUSTRAC: Financial channels and criminal activities; FATF: Printed pages 10 to 11: Key characteristics.
Example: repeated unexplained instructions
A fictional firm receives similar instructions for several customers from the same intermediary. The stated reasons do not match the records supplied. A reviewer records the repeated facts and examines each customer relationship.
The reviewer does not assume all customers are members of a network. They follow the approved escalation route and preserve the evidence. Each conclusion remains limited to what the firm can support.
Sources: AUSTRAC: Financial channels and criminal activities; FATF: Printed pages 10 to 11: Key characteristics.
- Connection observed
A common intermediary appears in several customer files.
- Evidence reviewed
Compare instructions, activity and explanations.
- Conclusion recorded
State what is supported and what remains unknown.
A business connection is not a criminal conclusion
Illustrative review of the fictional intermediary example. A shared adviser alone does not prove a laundering network.
Separate evidence questions. An answer to one does not settle the others.
Why one file may be incomplete
A single service provider may see only one part of the activity. Compare relevant records available lawfully to the business. Do not seek records through unauthorised access or disclosure. Use the customer and reporting procedures for the actual decision.
Sources: AUSTRAC: Financial channels and criminal activities; FATF: Printed pages 10 to 11: Key characteristics.