Australian AML/CTF · Explainer

Virtual assets and money laundering

Virtual assets can move criminal proceeds between services and countries. Transfer records and customer identity are separate evidence questions.

General information only, not legal, compliance, or other professional advice. Does not confirm compliance.

Value can move across different services

Virtual assets can be used to transfer or convert criminal proceeds. AUSTRAC’s 2026 update identifies risks in decentralised finance and offshore providers.

The update describes reduced visibility when activity crosses services and jurisdictions. It is a national threat assessment, not a finding against every virtual-asset user.

Source: AUSTRAC: Technological innovation and regulatory changes; International factors.

A transfer record has limits

A visible transfer record may show value moving between addresses. It does not, by itself, establish who controlled each address or why the transfer occurred.

A useful case record separates the observed transfer from the attributed person. It states the evidence for the identity connection and any gap.

Conversion into ordinary currency does not establish a lawful source. Nor does the use of virtual assets establish an unlawful source.

Source: AUSTRAC: Technological innovation and regulatory changes.

Separate three evidence questions
  • Transfer

    What movement of value is recorded?

  • Control

    What evidence connects a person to the address?

  • Purpose

    What supports the stated reason for the transfer?

Separate three evidence questions

A transfer record can answer one question while identity or purpose remains unresolved.

Connected concepts. Lines do not show ownership or a reporting hierarchy.

A deposit with an unclear origin

A fictional customer deposits virtual assets and requests conversion into Australian dollars. The customer describes the assets as investment returns.

The reviewer compares that explanation with the available customer and transaction records. A transfer history may support part of the account without establishing the original investment.

The file records what is known, what remains unclear and the resulting action. It does not describe an uncertain address attribution as a confirmed identity.

Source: AUSTRAC: Technological innovation and regulatory changes; International factors.

Use the relevant service rules

The provider-scope article describes Australian designated services. The travel-rule article describes information duties for applicable transfers.

This article concerns laundering patterns and evidence limits. A transaction pattern alone does not replace the separate SMR test.

Source: Federal Register of Legislation: Sections 6 and 41; Part 5.

Sources and scope

Sources checked on 2026-09-13. This page is not continuously updated. Check the linked legislation and AUSTRAC guidance for current requirements.

How we prepare articles

This page does not cover: Virtual asset service registration; Detailed travel-rule requirements; Instructions for hiding transfers.

Common AML/CTF terms