A real estate agency discovers that over several months, an employee has been accepting multiple cash deposits of $9,500 each from the same overseas investor client, structured to avoid the $10,000 AML reporting threshold. What are the agency's obligations under the AML/CTF Act?
Correct Answer
C) Lodge a suspicious matter report, treating the pattern as possible structuring
This scenario describes 'structuring' or 'smurfing' - deliberately breaking down transactions to avoid reporting thresholds, which is a red flag under AML legislation. The agency must file a suspicious matter report (SMR) with AUSTRAC as this pattern of transactions appears designed to avoid detection and may indicate money laundering activity.
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