Real-Estate Agents: How to Spot Structuring in Cash Deposits
Powered by My Databoss – Helping You Stay AML/CTF-Compliant
Why Structuring Matters
“Structuring” (also called smurfing) happens when a buyer tries to break one large cash payment into smaller amounts to avoid the AUSTRAC cash-reporting threshold of AUD 10,000 per transaction.
Under the AML/CTF Act 2006, any Threshold Transaction Report (TTR) must be lodged within 10 business days if ≥ $10,000 cash is accepted.
If someone deliberately splits a $50,000 deposit into five $9,999 payments to dodge a TTR, that’s a criminal offence — and the agent who accepts it without raising a red flag risks civil penalties and reputational damage.
Why Real-Estate is Targeted
Property is a stable store of value: Criminals like to “park” illicit cash in real assets.
Deposits often handled by agencies or trust accounts: A convenient placement stage for laundering.
Busy settlement timelines: Red flags can be missed without a structured process.
Key Red-Flag Behaviours to Watch
Multiple small cash payments from the same buyer close together (e.g., five deposits of $9,500).
Cash deposits made by different people on behalf of one buyer.
Reluctance to show bank statements or explain why cash is used.
Pressure to hurry settlement or avoid normal ID steps.
Deposits made at branches far from the buyer’s address or outside business hours.
Mismatch between the buyer’s profile and cash availability (e.g., student buyer paying $80,000 in cash).
Practical Steps for Agents
Know your customer: Always complete digital ID verification before accepting any deposit.
Ask about source of funds: If cash, document a clear, plausible explanation.
Refuse to accept cash that looks structured: Escalate to your Compliance Officer.
Record every red-flag event: Even if you reject the cash, log the incident.
Report when required: If you accept ≥ $10,000 cash → lodge a TTR; if activity looks suspicious → raise an internal SAR and consider an SMR to AUSTRAC.
Keep evidence for 7 years: ID docs, conversations, and any suspicious-activity records.
How My Databoss Helps
Digital ID + biometric checks: before trust-deposit accepted.
Automatic cash-threshold alert: Flags any payment ≥ $10k or patterns suggesting structuring.
One-click TTR: draft and SAR log for Compliance Officer review.
Secure record-keeping: Everything stored for 7 years and audit-ready.
Board & CO dashboards: Quick overview of all flagged deposits and reporting actions.
Quick Checklist for Front-Desk / Sales Team
Verify buyer ID in My Databoss before taking any deposit.
Check if total cash across all payments ≥ $10,000.
Ask for and record the source of funds explanation.
If cash looks structured - pause, escalate, and log SAR.
File TTR within 10 business days for any cash ≥ $10,000.
Keep calm, be professional - Never tip off the buyer about an SMR.
Free Starter Kit for Real-Estate Agencies
Risk-Assessment Template (Excel) – pre-filled with property-sector risks
Step-by-Step AML/CTF Guide – unlocked in your free implementation session
E-Learning Module for Agents – launching Nov 2025
[ Download the Free Risk-Assessment Template → ]
[ Book Free Implementation Session → Receive Compliance Guide ]
Helpful AUSTRAC Resources
AUSTRAC – Real-Estate Guidance
AUSTRAC – Red-Flag Indicators for Property Sector
Reporting Forms: SMR & TTR
Key Take-away:
If the pattern of payments doesn’t make sense, pause and escalate!
My Databoss automates the paperwork so you can focus on closing safe, compliant deals.