Tranche 2, plainly · Episode 4
There is one number every Tranche 2 business should have in muscle memory. Ten thousand dollars. Cross it, in cash, and a duty switches on.
The threshold
When a customer pays ten thousand dollars or more in physical cash — or its value in digital currency — you have what the Act calls a threshold transaction. And a threshold transaction must be reported to AUSTRAC.
(2) The reporting entity must, within 10 business days after the day on which the transaction takes place, give the AUSTRAC CEO a report of the transaction.
The trap — splitting
Now here is where people get themselves in real trouble. Someone realises ten thousand triggers a report — so they split it. Two payments of six. Three of four. That isn't clever. It is a criminal offence, with its own section.
(1) A person (the first person) commits an offence if: (a) the first person is, or causes another person to become, a party to 2 or more non-reportable transactions; … for the sole or dominant purpose of ensuring … the transactions … would not give rise to a reporting obligation.
So the rule is short. The ten-thousand-dollar line is real. Splitting to dodge it is a crime. And spotting the split is exactly what you are here to do.
One number. One report. One trap to watch for. Get the ten-thousand-dollar line right, and you have mastered the most common money-laundering move there is.