---
title: "Monitor a customer for unusual transactions and behaviour during the matter"
url: "https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/monitor-a-customer-for-unusual-transactions-and-behaviour-during-the-mat"
type: "task"
site: "AI Law Framework"
id: "A52OB-SF20261022-4"
practice_area: "AML/CTF — the practice as a reporting entity"
tier: "yellow"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Monitor a customer for unusual transactions and behaviour during the matter

> 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…

Canonical page: https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/monitor-a-customer-for-unusual-transactions-and-behaviour-during-the-mat  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [AML/CTF — the practice as a reporting entity](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| 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 / versions | 1 jurisdiction versions below |

## Checking plan

**Source-by-source verification**

Trace relied-on content to independent sources and check for relevant material the output has missed.

- What the AI does: 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 does: 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.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Practical workflow informed by the linked primary sources; the traffic light and working checks are editorial guidance, not a court classification.
- Why: The level reflects what the work is, the consequence of an error, and how much of the output the lawyer must independently re-derive.

## Checks the lawyer makes

1. Check each flagged transaction against the trust ledger or the instruction, not against the summary.
2. Compare the flag with what the practice already knows about this customer, not with a generic indicator list alone.
3. Record either the legitimate explanation and the document that supports it, or the decision to escalate.
4. Do not write a suspicious matter report from this note. That report is a separate task.

## Notes

- 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.

## Sources

- [AUSTRAC: What you must monitor for](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/customer-due-diligence/ongoing-customer-due-diligence/what-you-must-monitor) (checked 2026-10-22)

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/monitor-a-customer-for-unusual-transactions-and-behaviour-during-the-mat/united-states.md) | Yellow |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*