What red flags should staff watch for when assessing whether to lodge an SMR?
Behavioural indicators (secretive, evasive, inconsistent profile), transactional indicators (unusual structuring, third-party funds), and customer-pattern indicators feed into UAR and SMR prompts.
The platform's training modules cover red flag patterns in detail. The short-form checklist below is the same framing used in the training and in the in-platform UAR (Unusual Activity Report) prompts.
Behavioural indicators - "Does the customer's behaviour feel off?"
- Secretive or evasive: customer refuses to provide information, gives vague details, avoids face-to-face meetings without explanation.
- Inconsistent profile: known income, age or occupation doesn't match the asset value or transaction complexity.
- Reluctance to provide ID, or defensive responses to standard ID requests.
- Unusual urgency to complete the transaction, especially with pressure to cut corners on due diligence.
- Acting as a "front" - customer appears to be taking instruction from someone else not present in the paperwork.
- Fake or tampered documents - ID quality looks photocopied, altered or inconsistent with originals.
Financial indicators - "Where is the money coming from?"
- Unexplained wealth - customer can't or won't clearly explain origin.
- Unusual payment methods - large cash deposit, crypto, third-party cheque.
- Third-party funding - funds from a person or entity unrelated to the transaction parties.
- High-risk jurisdictions - funds flowing from or to countries on FATF lists.
- Private lending - undocumented private loans or promissory notes instead of standard finance.
Transactional indicators - "Does the deal itself make sense?"
- No economic sense - transaction results in a loss, or asset price is materially different from market.
- Structuring - splitting payments to stay under the $10,000 TTR threshold.
- Flipping - asset bought and resold in a short window with no clear profit motive.
- Buying "blind" - high-value asset purchased without inspection, especially if buyer is offshore.
- Unnecessary structural complexity - trusts, shell companies or nominee directors used for a transaction where direct purchase would be simpler.
- Trust account misuse - customer deposits funds then cancels and asks for a refund to a different account.
When two or more of these appear together, the threshold for "reasonable grounds to suspect" is generally met and the SMR pathway applies (3 business days for ML, 24 hours for TF). See AUSTRAC's Suspicious matter reports page.