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Creditcrest AML

Your AML/CTF duties, worked out from the records you already keep.

Due diligence, documented.

Customer due diligence, a risk rating with its factors, and AUSTRAC’s clocks.

What you do here. Read an example customer’s due diligence gaps, risk rating and alerts, with AUSTRAC’s reporting clocks.

Try it end to endTake the tour
You bring
Customer records and the loan ledger
You get
Due diligence gaps, a risk rating with every factor, alerts
Holds the line
Suspicious matters on AUSTRAC’s clocks

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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