Monitor a customer for unusual transactions and behaviour during the matter
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- From the customer profile taken at the start of the matter and the transactions and instructions since, list activity that does not match that profile: size, pattern, complexity, countries, source of funds, or a structure that hides ownership. Tag each row to the document it came from. The tool does not decide that the activity is unlawful or that a report is required.
- What the lawyer must review
- The lawyer decides whether there is a legitimate explanation or whether the next step is enhanced due diligence or a suspicious matter report. Monitoring is required under section 30(2)(a) so the practice can identify, assess and manage money laundering, terrorism financing and proliferation financing risk. Unusual activity is not itself proof of a crime. A suspicion, if formed, is reported through the separate suspicious matter process and is not decided on this list.
- Written for / version
- US
Open a jurisdiction version of this task to see which instruments apply: US
Who does what
| Role | What they do |
|---|---|
| Assistance | From the customer profile taken at the start of the matter and the transactions and instructions since, list activity that does not match that profile: size, pattern, complexity, countries, source of funds, or a structure that hides ownership. Tag each row to the document it came from. The tool does not decide that the activity is unlawful or that a report is required. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Check each flagged transaction against the trust ledger or the instruction, not against the summary.
- Compare the flag with what the practice already knows about this customer, not with a generic indicator list alone.
- Record either the legitimate explanation and the document that supports it, or the decision to escalate.
- Do not write a suspicious matter report from this note. That report is a separate task.
Sources
- AUSTRAC: What you must monitor for · 2026-10-22
These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.