A reporting entity must submit an SMR if they form a reasonable suspicion of money laundering, terrorism financing or other offences such as fraud or tax evasion. Working with its partner agencies, AUSTRAC pieces together intelligence from a range of sources to develop a picture of criminal activities and networks. For this risk assessment, AUSTRAC analysed in detail all SMRs lodged over a two-year period, where: the SMR had been lodged by a financial planner; or the SMR had been submitted by another financial institution, but a financial planner had identified the suspicious matter or had been involved in the transaction in some way. That equates to only one SMR being submitted per fortnight by financial planners nationwide in relation to their customers. Most entities consulted for this assessment agreed that this figure was surprisingly low. These were generally reported by banks and product issuers, and may reflect more advanced reporting practices by these institutions.

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