The AML/CTF Australian business study surveyed businesses from all sectors in Australia during 2009 with AML/CTF regulatory requirements, including the gambling, banking, managed funds and superannuation, securities and derivatives, foreign exchange, alternative remittance, financial services and cash delivery sectors, and other businesses providing regulated services, such as bullion dealers. The study was the first in Australia to consider the views of reporting entities on the risks of money laundering and terrorism financing facing their businesses, their approaches to compliance, the costs of compliance the perceived effectiveness of the regime and ways in which the regime could be improved. The findings presented in this report summarise the views of regulated businesses in the phase immediately following the full implementation of the AML/CTF Act 2006 (Cth) in 2009. Further qualitative information on the perceptions of regulated businesses came from interviews undertaken with a small number of individuals who had completed the questionnaire and who were willing to undertake face-to-face interviews. Their views, although not necessarily representative of all the survey respondents, nonetheless provided some useful insights into how they understood Australia’s AML/CTF regime in 2009.
Perceptions of risk
Perception of risks of money laundering
More than half of the respondents to the AML/CTF Australian businesses survey perceived the risk of their business becoming implicated in money laundering to be non-existent, or very low. The other half highlighted a diverse range of potential money laundering risks that they believed their businesses might face in the two year period to 30 June 2011. Many of these risks were tied directly to the core business of each industry sector and not to any external threat, type of customer, or type of predicate crime. The largest proportion of respondents (albeit only 5.9%) nominated gambling as the highest risk for money laundering, with the majority of these businesses being from the gambling sector themselves.
In relation to perceptions of the level of risk of money laundering to which the businesses of respondents were exposed, almost all of the survey participants (97.8%) stated that they considered their businesses were exposed to low risks of money laundering in the year to 30 June 2009. Ninety-five percent of the survey respondents anticipated that the level of risks would decrease or remain the same in the two year period to 30 June 2011. Nine businesses, from the 3,870 respondents who answered the question perceived the risks of money laundering to their businesses to be high. Most interviewees shared the view that their business faced few risks in mid 2009 and their expectation was that this situation would not change in the two year period to 30 June 2011.
Each of the business sectors surveyed in this study demonstrated different profiles in respect of who they considered to be high-risk customers, although each sector highlighted Australian and foreign individuals, PEPs and foreign companies as the four riskiest types of customers. As might be expected in a risk-based system, individual businesses assigned risk based on their own experiences. For example, respondents providing gambling services were less likely to identify PEPs as high-risk customers compared with respondents from the banking sector—although as noted above, casinos might have viewed PEPs as a higher risk than clubs and pubs—which was not able to be assessed in this survey where the results of all gambling service providers were grouped together. The perception of high risk did not include customer types that might be linked to complex business arrangements, which might be used to conceal beneficial ownership such as trusts, associations, or domestic companies.
More than one-third of survey respondents nominated individuals as high-risk customers—a larger proportion than those that identified either PEPs or foreign companies as being high risk. Businesses from the financial services sectors—such as banks and securities and derivatives businesses—were more likely to consider PEPs as high-risk customers than money service businesses or the non-financial businesses regulated in Australia. Financial services businesses were also more likely than money service businesses or non-financial businesses to consider foreign residents and foreign governments as posing higher risks as customers.
Perception of terrorism financing risks
Almost all of the study’s participants (99.5%) considered the risks of terrorism financing to their businesses to be low in 2008–09 and more than 95 percent of respondents also anticipated that such risks would remain stable in the two year period to 30 June 2011. When respondents were asked to nominate the types of terrorism financing risks that their businesses might face in the two year period to 30 June 2011, just under 60 percent still indicated that their business faced little or no risks of terrorism financing. There was a relationship between business sector and perceptions of terrorism financing risk, with the proportions of respondents from different business sectors that identified no or low risks of terrorism financing ranging between 40 percent of foreign exchange businesses to 66 percent of financial services businesses. Only two participants from the entire sample reported believed high risks of terrorism financing might be affecting their businesses.
The perceptions of participants of higher risk customers also varied according to the business sector they occupied. Businesses from the financial services sector were more likely than money service businesses or non-financial businesses to select ‘individuals’ as higher risk customers in relation to terrorism financing.
Explaining these perceptions
The overwhelming view of survey participants was that their business faced few money laundering and terrorism financing risks. This opinion may have been based on the surveyed entities genuinely having faced few risks of either crime taking place. Alternatively, those surveyed may not have been in possession of adequate information to enable them to evaluate the level of risk that faced their business at the time. It may also be the case that the participants may have underestimated the true level of risk involved.
The current study offers some insight into the reasons why almost all of the participants in the study considered their business to be exposed to low risks of money laundering or terrorism financing. One view that emerged from the survey data was that the perception of there being very few money laundering and terrorism financing risks was directly linked to the size and core activities of the businesses involved. Smaller sized businesses felt they were insulated from ML/TF risks because owners and managers of small enterprises personally knew their customers and any new customer entering the business would be immediately obvious to, and ‘vetted’ by, staff. Providing some support for this view is that almost all of the few money laundering cases that have been prosecuted in Australia that have involved small businesses have not involved unwitting involvement of personnel. Rather, these cases all involved complicit agreement by the business to participate in laundering the proceeds of crime. The Australian case examples that involved unwitting use of designated service providers had used large banks with multiple branches in order to structure deposits discreetly (see Box 1 and ACC 2011, AUSTRAC 2011b, AUSTRAC 2011c).
Box 1: Australian money laundering cases
The recently prosecuted money laundering cases in Australia summarised below offer some insight into the types of high-risk customers that the regulated business sectors may encounter.
A Ansari v R H Ansari v R (2007) 70 NSWLR 89; Ansari v The Queen  HCA 18; Regina v Z  NSWCCA 342
The Ansari brothers were convicted of two charges of conspiring to launder money valued at more than $1m through their remittance business Exchange Point. The Ansaris took receipt of $2m cash from a man known as ‘Z’ in October 2003. The Ansaris then arranged for another person, ‘H’ to collect the money and deposit it on their behalf between October 2003 and May 2004. ‘H’ deposited $1,952,107 in amounts of less than $10,000 during that period. Via Exchange Point, the Ansari’s moved illicit funds around within their country of origin without leaving any transaction records with a remittance service provider in that country.
The Crown alleged that the Ansaris knew that the funds would be deposited in amounts less than $10,000 to avoid triggering reporting requirements in Australia. The Crown demonstrated that the brothers were reckless of the risk that the money would become an instrument of crime. The money laundering offence the Ansaris were convicted of conspiring to execute was the reckless laundering of funds valued at $1m or more (s 400.3(2)).
Defendant ‘Z’ was an Israeli national who pleaded guilty to money laundering and drugs charges in 2004. Z’s role was to deposit the proceeds from drug sales with Exchange Point and in 2004, Z advised the Ansaris that a deposit would be for more than $2m and would require more steps than the previous laundering activities. Z and a Belgian national, ‘K’ were arrested for possessing commercial quantities of MDMA. A statement later made by Z indicated he was employed by a Romanian national, ‘R’, to move money from Australia and he delivered more than $2m to Exchange Point on his first trip in 2003. R offered Z $10,000 in 2004 to undertake the same kind of laundering activities as those undertaken in 2003.The Ansari’s appealed their sentences to the NSW Court of Appeal, which dismissed the appeals and affirmed the terms of imprisonment for the money laundering offences for which they were found guilty.
R v Huang, R v Siu  NSWCCA 259
Huang and Siu each pleaded guilty to offences under the FTR Act (s 31(1)) and of money laundering under the Criminal Code (s 400.3(1)). Huang was paid $30,000 by his employer for remitting $3,088,311 to Hong Kong and China in 335 separate transactions in 2003. Huang used a branch of one of two major Australian banks to complete the transactions. He believed he was remitting legitimately gained funds that were being transferred offshore to evade Australian taxes. Siu believed the money to be the proceeds of an illegal fishing operation. Siu conducted 59 transactions, also through the same large Australian banks, between May and July 2003 to remit a total of $556,400. Siu was paid around $3,000 for his participation.
Trang Thi Phuong Nguyen 2010
In 2010, Nguyen pleaded guilty to money laundering for transactions she conducted between November 2007 and January 2008. Nguyen divided funds totalling $1.9m into accounts with balances of less than $10,000 and remitted the funds to individuals in Vietnam using false names (ACC 2010).
Long Thanh Money Transfer Company 2009
Seven people employed by the Long Thanh Money Transfer Company were convicted of money laundering in 2009. The individuals involved in the remittance businesses received sentences for laundering up to $68m (ACC 2009a). Three other defendants were convicted in October 2009 (ACC 2009b) for laundering sums of $9m, $5.5m and $4m respectively.
Nhon Anh Khuu and Chi Vien Duong 2009
Khuu and Duong defrauded the Australian Taxation Office (ATO) of $1.7m and $2.2m by creating an artificial network of subcontractors to disguise the nature of a labour hire business from the ATO, as well as receiving goods as payment for labour that were later sold. The defendants pleaded guilty to charges of defrauding the Commonwealth, obtaining property by deception, dishonesty causing a risk of a loss to the Commonwealth and dealing funds intended to become the instruments of crime.
Prchal, Raffaut, Rojas and Smetana 2008
Raffaut prepared amended tax returns containing false details for Prchal in 2001 and 2002, resulting in the ATO refunding Prchal $35,038.87. Raffaut then obtained the details of other tax payers and he and Prchal recruited Rojas to present those details to tax agents in order to obtain refunds from the ATO. Smetana was recruited to supply bank account details to receive the payments from the ATO. Smetana received eight percent of the total payment; Rojas received $200–250 per day for his role. The ATO paid $262,580.23 into Smetana’s three accounts. The group claimed a further $162,121.89 that the ATO did not pay out. Smetana was convicted of recklessly dealing with the proceeds of crime to the value of $100,000 or more (CDPP 2009).
The feedback provided by interview participants from the gambling sector stressed that the small turnover that their businesses experienced from regulated services and the industry in which they operate were the two primary reasons for levels of money laundering risk being so low. These participants took the view that gaming machines offered little genuine opportunity to launder money or to launder large sums of money undetected. The limited opportunities afforded to any customer with the intention of laundering money would be further reduced in licensed premises that might only have one or two gaming machines. Any attempt to launder funds in such an environment would be immediately apparent.
Some of the interview participants considered that the nature of their customer base would make money laundering unlikely to occur and if it did, it would be identified. Smaller businesses, in particular, emphasised that owners and managers personally knew their customers and that any new customer entering the business would be immediately obvious to all staff and other clientele.
Another factor that may explain perceptions of low ML/TF risks was the self-described risk-averse culture of their businesses. In each case, the motivation for a highly risk-averse culture stemmed from inherent risks associated with the core activities of the business rather than from money laundering concerns. The cautious approach that these businesses adopted when dealing with new clients, combined with monitoring and modifying procedures, acted to diminish the opportunities for any clients to use their businesses to conduct illegal transactions.
It is apparent from the present research that perceptions of risk and confirmed cases of actual exploitation may not always coincide. AUSTRAC’s (2010c) examination of 174 case studies and typologies published for the period 2007–10 found that money laundering offences, along with fraud offences, constituted the most prevalent form of criminal activity (26% each), while terrorism made up just one percent. The regulated industry sector most commonly used to launder money or transfer funds for the financing of terrorism—based on the sample of cases chosen in AUSTRACs typologies and case studies series—was the banking industry (45%; AUSTRAC 2010c), followed by alternative remittance services (18%) and gambling services (9%). Based on this evidence, it might be expected that representatives from these business sectors would perceive or experience a higher level of risk than other sectors in general (although it should be noted the survey in 2009 occurred in the early stages of AUSTRAC’s typologies and case studies series).
However, in the current survey, the majority of survey respondents from the banking, remittance services and gambling sectors were no more likely than representatives of other surveyed industry sectors to report a higher perception money laundering or terrorism financing risk. They were also no more likely to predict an increased risk between 1 July 2009 and 30 June 2011, with the exception of providers of alternative remittance services.
In another AIC survey, respondents from law enforcement agencies considered that the risk of ML/TF to currently regulated sectors had not changed considerably since the implementation of the AML/CTF Act 2006 (Cth), although it had probably reduced for the banking sector and increased for alternative remittance service providers (Smith et al. forthcoming).
Exploring why business sectors that are implicated in confirmed cases of misuse do not have a higher risk perception might identify ways to close this gap and improve the effect of government guidance. Whether those sectors and industries regulated under AML/CTF actively use AUSTRAC and other government information to inform their risk programs could also be evaluated.
Some relationship existed between the perceptions of reporting entities of risks and compliance activities, although there was no clear reduction in compliance from businesses that had low perceptions of risk. More than 85 percent of businesses conducted ongoing customer due diligence procedures. The compliance rate fell to 75 percent for pre-employment screening and 80 percent for KYC procedures. Relationships were found between the business sectors of participants and their likelihood of conducting each of these three compliance measures assessed in this survey. Businesses from the financial services sectors were more likely to conduct ongoing due diligence and KYC procedures than either money service businesses or non-financial businesses. Financial services businesses, such as banks, and cash delivery service providers were more likely than other participants to conduct pre-employment screening before hiring new staff.
The data revealed no statistically significant relationship between compliance with KYC requirements and the views of participants on money laundering risks to 2011. Those who perceived no money laundering risks were no less likely to comply than those who nominated some level of risk. There were relationships between respondents who nominated ‘no risks’ and those who conducted pre-employment screening and ongoing due diligence. Businesses that nominated ‘no risks’ were significantly less likely to conduct pre-employment screening and less likely to conduct ongoing due diligence.
More than 90 percent of the businesses that responded to the AML/CTF Australian businesses survey were small or micro businesses and many did not have AML/CTF regulatory obligations under the FTR Act (ie they were newly exposed to such obligations with the enactment of the AML/CTF Act 2006 (Cth)). It is arguable that within this context, some of the reporting entities surveyed experienced difficulties applying the risk-assessment procedures that formed the current basis of AML/CTF compliance in Australia. Comments from the small number of interviewees from small businesses in previously unregulated industries indicated a degree of difficulty in understanding the requirements of the regime, applying the logic of risk assessment as the basis of risk-based compliance and addressing those risks through customer due diligence and ongoing monitoring. Interviewees from industries that had previous exposure to AML/CTF regulation, other financial regulatory obligations, or extensive regulation for other areas of their business were better able to apply the concepts of a risk-based system and to identify the specific AML/CTF and other risks that their businesses might face. The relationship between the views of respondents on whether the Australian AML/CTF regime was too onerous and their business sectors might also suggest difficulties from within some industry sectors in complying with the regime.
Identifying and reporting suspicious transactions
The business sector of the participants also appeared to have an impact on the likelihood of each business identifying a suspicious matter. Banks, despite holding more restrictive views on over-reporting than other businesses, were those most likely to have identified a transaction suspected of being linked to money laundering in the year to 30 June 2009.
Most participants (70–80% depending on the scenario presented) disagreed or strongly disagreed that under-reporting of suspicious transactions to AUSTRAC was justifiable, even in situations where reporting might be thought to result in a loss of business, or where the business feared reprisals from such action. Over-reporting was also considered justifiable by the majority of respondents (50–70% depending on the scenario presented), although in each instance, the banking sector was the least likely to consider over-reporting justifiable. The results suggested that even as participants outside the banking sector were more inclined than not to report a suspicious matter, those in the banking sector were the most likely to encounter and to identify a suspicious matter.
Information on costs provided by survey respondents was also tied to, or affected by, the business sector respondents occupied. The reported compliance expenses across the entire sample ranged from no cost to $60m. The median expenditure across the entire sample was $1,000, with 57 percent of businesses reporting expenditure of $1,000 or less on AML/CTF compliance. Managed funds and superannuation businesses reported the highest median AML/CTF compliance costs at $6,000. Businesses from the foreign exchange sector and those classified as ‘other’ reported median costs below $500.
Approximately two-thirds of the sample expected their compliance costs to remain the same in the two year period to 30 June 2011. Seventy percent of participants who anticipated shifts in their compliance costs expected their expenses to increase by less than 50 percent. Participants ranked staff training and professional development, staff salaries and record keeping, monitoring and reporting as the most expensive areas of their compliance costs. The timing of the AML/CTF Australian businesses survey coincided with the period immediately after the full implementation of the AML/CTF Act 2006 (Cth) and hence some of the compliance cost estimates provided by respondents may refer to initial financial outlays that were not sustained into subsequent years. It is also possible that some of the systems changes required to address AML/CTF compliance were done in conjunction with other, general upgrades which may have temporarily inflated costs. The reported expenditure of participants for AML/CTF compliance in 2008–09 was associated with their views on whether the regime was too onerous. The likelihood of participants viewing the regime as being too onerous, however, did not directly increase with their costs. The participants who reported spending $1,000 or less were more likely to give neutral responses to the question of whether the regime was too onerous for the risks involved. Across the entire sample, around 28 percent of participants considered the regime to be too onerous, while approximately 25 percent disagreed that this was the case. Only one percent of respondents disagreed that the regime was too onerous as the low level of risk to their businesses meant compliance activities were kept to a minimum.
Attitudes towards the anti-money laundering/counter-terrorism financing regime
Participants held fairly positive views of the AML/CTF regime, despite the overwhelming perception that there were minimal risks of money laundering or terrorism financing to their businesses at the time. The survey’s respondents considered the regime to be effective in deterring offenders, minimising the risks of financial crimes, minimising the risks of money laundering, minimising the risks of terrorism financing, maintaining the integrity of the financial system and promoting good governance practises. Respondents rated the regime as neither effective nor ineffective at facilitating proceeds of crime recoveries or minimising the risks of reputational damage. Those who considered the regime to be too onerous for the risks of ML/TF were also more likely to consider the regime to be less effective at minimising these risks.
Almost half of respondents agreed that the AML/CTF system would be improved if AUSTRAC were able to provide more AML/CTF training courses. Approximately one-third agreed that the system would be improved if AUSTRAC could provide more case studies and typologies. The businesses that participated in this study had a range of experiences with AUSTRAC and AUSTRAC’s materials. Some businesses, predominantly those from industries with previous contact with financial and other forms of regulation, found AUSTRACs training documents integral to their employee training programs. Businesses from the financial services industries were more likely than money service businesses, or non-financial businesses, to suggest that the AML/CTF regime could be improved with more typologies and case studies being provided by AUSTRAC.
The AML/CTF Australian businesses survey was the first study to canvass the views of Australian regulated businesses on various aspects of complying with the AML/CTF regime. It attracted a large number of respondents drawn from all regulated sectors in 2009 and achieved an unusually high response rate for business surveys of this kind (50%). The findings provide a benchmark of how businesses in Australia understood their obligations in mid 2009, their views on the regime at the time and projections for the ensuing two years to 30 June 2011. Some of the principal findings are as follows.
Variations between business sectors in terms of compliance, costs and perceptions of risk were present throughout the results of the survey. The experience of businesses from the banking, securities and derivatives, managed funds and superannuation, and financial services sectors were quite different from those in the gambling sector, ARS providers, foreign exchange businesses, cash delivery sector and other businesses with regulatory obligations in key areas.
Generally, businesses without previous exposure to AML/CTF compliance were less likely to have used standard compliance measures and to report feeling confident in identifying suspicious transactions. Absence of prior exposure to AML/CTF compliance also led to these respondents to consider that the regime was too onerous relative to the risks present. While most respondents surveyed perceived the overall risk of money laundering or terrorism financing to their business to be low, some sectors from the newly regulated component of businesses were more likely to nominate a lower risk. The perception of the AML/CTF regime as being too onerous was less likely, however, to be associated with the costs involved. Most businesses reported spending $1,000 or less on AML/CTF compliance and the businesses from some of the newly integrated sectors spent even less.
An issue for the integrity of the system as a whole is that some of the business sectors (or some members of affected sectors) included in the regime—in order to create a more hostile environment to illicit transactions—reported experiencing difficulties in conducting risk assessments, implementing risk-appropriate measures and complying fully with the regulatory obligations in 2009. Gurung, Wijaya and Rao (2010) argued that all businesses may find interpreting and applying their AML/CTF regulatory obligations challenging, although financial institutions that had AML/CTF regulatory obligations prior to the 2006 Act were far better placed to become compliant with the current obligations because of their previous exposure to regulation in this field.
The Australian AML/CTF regime is risk based in the sense that regulated sectors are able to self-assess the ML/TF risk their business is exposed to and develop an appropriate compliance program to mitigate and manage this risks; reporting requirements are the same, irrespective of risk. While it was not entirely clear from the survey findings which components of the regime respondents found particularly onerous—the development and adherence to the business-specific risk mitigation program or compliance with mandatory reporting requirements—it is assumed from the responses that much of the difficulty was associated with the latter.
One of the core tenets of the risk-based system is to apply it appropriately to different business environments. One response to the findings may be the need to place greater emphasis on developing sector-specific education that will enable businesses to assess levels of risk more effectively and to create programs accordingly. An immediate response to assisting businesses without previous exposure to, or continuing difficulty with, AML/CTF regulatory requirements is through the provision of educational materials and training tailored to affected sectors. At the time the survey was undertaken, which coincided with the initial implementation of the AML/CTF Act 2006 (Cth), respondents suggested that sector-specific educative and training initiatives would assist them in better understanding and assessing the risk environment in which they operated, a central component of the risk-based AML/CTF system. The delivery of sector-specific education has been recommended in other AIC research on money laundering and terrorism financing risks; for example, providers of alternative remittance services (Rees 2010), non-financial sector businesses and professions suggested for inclusion under the second tranche of reforms and non-profit organisations (Bricknell et al. 2011).
In the period since the survey, AUSTRAC has made available a more extensive range of education, training and guidance materials for regulated entities that has included:
- generic and industry-specific guidelines regarding AML/CTF obligations;
- information brochure series on program procedures;
- risk-management tools to aid small and medium sized businesses in identifying, assessing and treating risk; and
- industry-specific engagement and supervisory strategies, comprising targeted education and awareness campaigns and guidance materials with a focus on sectors that have experienced difficulty in applying a risk-based approach to implementing AML/CTF programs;
These initiatives, along with the annual publication of typology reports, should have filled at least some of the educative gap survey respondents felt existed in 2009.
The present survey was not without its limitations. Slightly over half of the survey’s respondents came from the gambling sector and these tended to be smaller businesses within that sector. Businesses from the financial services sectors, such as banks, were under-represented. This may have influenced the results in situations where analysis was conducted across the entire sample rather than comparing the outcomes between business sectors. Small and micro-businesses comprised the majority of the sample, which may also have influenced the results obtained in the study. There was no publicly available information at the time of writing on the distribution of business size within the regulated sector, to determine whether the number of smaller businesses that responded were representative of the entire regulated sector.
The data analysis uncovered some inconsistencies in how businesses from the same industry identified their primary sources of revenue in the self-reported demographic information. This was particularly problematic for businesses providing a range of services, such as a general store operating as a post office while also providing remittance services.
In addition, and despite intensive pre-testing of the survey instrument and consultation with regulators (see Challice & Eliseo 2012), the language used in the questionnaire to describe some aspects of the AML/CTF regime in Australia proved inaccessible to some survey respondents. The language adopted in the questionnaire predominantly reflected the language used by AUSTRAC and in Australian legislation concerning AML/CTF-specific terms. Some survey respondents also highlighted problems understanding some of the terms in the questionnaire in their answers to open-ended questions.
Depending on the extent of participants’ difficulty in understanding some of the key terms in the survey, the results may not have captured the views of businesses recently included in the regime to an appropriate extent. Analysis of the responses of the 50 percent of participants that elected not to complete the survey suggested that non-corporate businesses, such as pubs and clubs, post offices and retailers, were over-represented in this group. More than 70 percent of those that elected to not complete the survey agreed that the regime was too onerous (Challice & Eliseo 2012).
Finally, the survey findings reported here must be taken in the context that they were collected at the early stages of implementation of the AML/CTF regime. Initial trepidation about the costs of complying with the regime, among other concerns, may or may not have been borne out in the interim period. AUSTRAC’s (2010d) Supervision Strategy for 2010–11 noted the agency’s intention of conducting surveys across five industry sectors to gauge how well each sector has understood and implemented its AML/CTF obligations. If these subsequent findings are made available, they could be compared with responses collected in 2009 to determine if any changes or improvements have occurred in the regulated population’s response to or capacity to comply with Australia’s AML/CTF regime.
Directions for future research
Future studies of the opinions held by regulated businesses in this area and the methods and costs of compliance might seek to:
- replicate the survey and interviews to document changes in the ways businesses have viewed and applied the regime since 2009;
- replicate the survey to include all regulated businesses if the AML/CTF regime is expanded to include designated non-financial businesses and professions, such as legal practitioners, accountants and real estate agents;
- replicate the study in comparable countries to highlight differences and similarities in the self-reported risk profiles of different industries in different geographic locations; and
- conduct further and more detailed interviews with those in the regulated sectors and also with representatives of law enforcement, regulators and AUSTRAC’s partner agencies that make use of the reported data.