The Asia/Pacific Group on Money Laundering (APG) has published its Typology Report on Money Laundering Associated with Tax Crimes in the Asia Pacific, jointly prepared by the Australian Tax Office and the APG.

The report collates tax crime typologies and documents experiences of competent authorities in responding to ML associated with tax crimes.

It includes 7 Australian case studies that identify red flags including:

• Concealment of Beneficial Ownership
• Large Cash Activity
• Cheque Cashing Activity
• Use of nominees (e.g. director, shareholder, secretary)
• Use of nominee bank accounts
• Use of corporate vehicles (e.g. trust, shell companies)
• Use of unusual financial instruments (e.g. bank drafts, bank bills, bearer shares etc.) 
• Lodgement of false income tax returns
• Lodgement of false GST returns
• Use of cryptocurrencies
• Use of accountants as professional facilitators
• Use of solicitors as professional facilitators
• Use of company service providers as professional facilitators
• Use of secrecy jurisdiction for banking
• Use of secrecy jurisdiction for company incorporation
• Separation of jurisdiction of banking and jurisdiction of incorporation
• Use of foreign financial centres
• Purchase of high-value items
• Non-lodgement of income tax returns
• Non-lodgement of GST returns
• Use of unwitting third parties
• Takeover of a bank account of an uninvolved entity (e.g. student bank account after leaving jurisdiction)
• Use of loan-back arrangements
• Non-lodgement of other tax reporting obligations
• Use of false identities.

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Author: David Jacobson
Principal, Bright Corporate Law
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About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.