[CRSL] 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 Cronulla RSL employee.  Unusual activity may prompt further enquiry and enhanced customer due diligence procedures, which may, in turn, require Cronulla RSL 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 10A. [CRSL] PROCEDURE UNUSUAL MATTER Level 1&2 V1

The Club has developed the 10. [CRSL] UNUSUAL MATTER REPORT FORM_V1.2 Training.  to assist in establishing ‘reasonable grounds’ for suspicious matter reporting.

10a. [COE] AMLCTF PROCEDURE – UNUSUAL MATTER (Gaming) TRAINING V3