Creditcrest AML

A lender’s AML/CTF obligations, as arithmetic over the records it already keeps: whether initial customer due diligence is complete, a risk rating with every factor shown, monitoring rules over the loan ledger, and the clock on a suspicious matter.

Alerts on an invented account

RuleWhat was seen
possible structuring2 cash payments between $8,000.00 and $10,000.00 within 7 days, $18,700.00 in all. None needs a TTR on its own; the guidance asks whether this is structuring and an SMR is required. Events: p1, p2
third-party repaymentA payment of $500.00 on 5 Aug 2026 came from "K Other", not the borrower Jordan Example. Events: p3
large early payout$9,500.00 paid 19 days after an advance of $15,000.00 — at least 50% of the principal within 90 days. Events: p1
large early payout$9,200.00 paid 22 days after an advance of $15,000.00 — at least 50% of the principal within 90 days. Events: p2
refund to another accountA refund of $3,700.00 on 10 Aug 2026 went to 033-000 99999999, which is not an account the borrower nominated. Events: r1

Risk rating: medium (35 points)

Politically exposed personfalse0
Sanctions screeningclear0
Productpersonal loan5
How the customer cameonline10
Repays in cashtrue20
Country of residenceAU0

The factors and points are an example; each lender sets its own.

A suspicious matter: suspicion formed

Suspicion formed 28 July 2026. Within 3 business days after the day the suspicion was formed. Due 31 July 2026.

Do not tell the customer about this case or any report. Sharing SMR details can be a criminal offence.

The annual compliance report

The reporting period is moving to financial years, and AUSTRAC names 1 July 2026 to 30 June 2027 as the next one. Periods before it were calendar years and this does not compute them. Next period 1 July 2026 to 30 June 2027; lodged between 1 July 2027 and 30 Sept 2027.

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