How is "tipping off" managed during CDD?
Tipping off is a criminal offence under Part 14 of the Act; easyAML manages it through training, restricting SMR visibility to the Compliance Officer, and avoiding any customer notification of an SMR.
"Tipping off" is the criminal offence of disclosing to a customer (or anyone else outside the lawful exceptions) that a Suspicious Matter Report has been or will be lodged about them, or that an investigation is under way. Under Part 14 of the AML/CTF Act, tipping off carries significant penalties for both the firm and the individual.
How easyAML manages it:
- Training modules cover red flags, SMR triggers and tipping-off boundaries in detail - every user role completes the relevant module, with the Compliance Officer module going deepest.
- In-platform language for unusual activity is neutral - staff raise an Unusual Activity Report (UAR) internally, which the CO reviews. The customer never sees the UAR.
- SMR submission is restricted to the Compliance Officer. Other staff cannot lodge SMRs and aren't required to know whether one has been submitted - AUSTRAC explicitly does not want the CO to discuss SMR submission with the wider team. Closing a UAR signals to staff that the matter has been handled, without disclosing what was done.
- Customer-facing communications during a transaction under suspicion follow ordinary process - the platform doesn't add notifications or behaviour changes that could tip off the customer.
If a customer asks directly whether an SMR has been lodged, the correct response is to neither confirm nor deny. The training module covers safe phrasings for these situations. See AUSTRAC's Suspicious matter reports page for the broader framework.