Preserve the link to the original transaction
Record the original purchase or acquisition, item, customer, payer, payment method and relevant dates. Link the return, buy-back or refund request to that record rather than treating it as an unrelated contact. Identify whether the person requesting payment is the original customer or claims to act for someone else. Keep sufficient evidence to understand the sequence, including changed instructions, without adding unsupported conclusions about the customer's motives.
Ask what changed and why
AUSTRAC's dealer risk guidance identifies third-party involvement and rapid resale to the dealer as possible indicators. Examine the surrounding facts and legitimate explanations. For example, a requested refund to a different person's account raises a different inquiry from correcting a payment processing error. Confirm the authority and proposed destination through an appropriate channel, record the response and escalate unresolved concerns. Avoid relying only on new contact details contained in the changed instruction.
Keep the legal questions separate
Assess the designated-service threshold and relevant payment types using current guidance, including linked transactions where applicable. Threshold transaction reporting concerns physical currency and should not be confused with every virtual-asset or electronic payment. Separately assess whether reasonable grounds for a suspicious matter report arise. A transaction below a service threshold is not automatically irrelevant to every applicable reporting condition, and completing a refund does not erase the original transaction record.
Decide the response and retain the reasoning
Refer the case to the authorised person under the dealer's policies and consider any sanctions, reporting, consumer-law and contractual obligations. Do not assume AML concern creates an unrestricted right to withhold a lawful refund. Record the actual decision, evidence, approvals and any further monitoring. Protect reporting information in customer communication. Use recurring cases to review store procedures and staff escalation, rather than leaving refund staff to improvise a new rule at the counter.
Official sources
Use these primary sources to confirm the current rules and apply them to your circumstances.
Sources checked .
Frequently asked questions
Is every third-party payment suspicious?
No. Consider the facts, explanation and risk indicators together. Record the assessment and act when the relevant legal threshold is met.
Does a refund cancel the original AML record?
No. Keep the relevant purchase, return and payment history under the applicable record-keeping requirements.
Are electronic transfers automatically cash for a TTR?
No. Apply the physical-currency reporting rules separately from the designated-service treatment of other payment types and the suspicion assessment.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.