[MASTER] AMLCTF1RAT01 – Unusual Matter Procedure

Systems and Controls for Unusual Matters

An unusual matter is an activity that is not consistent with normal customer behaviour, or activity.  Activity that appears unusual is not necessarily suspicious. Many customers will, for example, have an erratic pattern of transactions or account activity. The behaviour or activity may cause concern to a [Venue Name] employee.  Unusual activity may prompt further enquiry and enhanced customer due diligence procedures, which may, in turn, require the [Venue Name] to decide whether the activity is suspicious and therefore should be reported to AUSTRAC in an SMR.

Should any circumstances arise as being an event that represents an unusual matter, gaming staff are to follow the PROCEDURE: UNUSUAL MATTER.

The Club has developed an PROCEDURE: UNUSUAL MATTER to assist in establishing ‘reasonable grounds’ for suspicious matter reporting.

CLICK HERE TO READ A COPY OF THE PROCEDURE: UNUSUAL MATTER.