In 2011, US federal prosecutors filed a civil forfeiture action against Teodoro Nguema Obiang Mangue, a government minister in Equatorial Guinea earning an official salary of under $100,000 a year. By then he had spent an estimated $300 million on property and luxury goods around the world, including a $30 million mansion in Malibu, California, bought through a web of shell companies and third parties rather than in his own name.¹ Nobody who handled that purchase needed to prove where every dollar came from. They just needed to notice that a government minister on a modest official salary was buying like someone with an income forty times that size.

Obiang eventually agreed to forfeit the Malibu mansion, a Ferrari and a collection of Michael Jackson memorabilia in a 2014 settlement with the US Department of Justice, one of the highest profile cases brought under the DOJ's Kleptocracy Asset Recovery Initiative.¹ The property was real. The purchase was real. The mismatch between his declared income and what he was actually spending had been sitting there in plain sight the whole time.

That's really what this article is about. Most of the red flags AUSTRAC and its overseas counterparts talk about aren't complicated forensic accounting tricks. They're the kind of thing a reasonably attentive person notices in five minutes, if they know to look. Below are ten of them, each tied to a real case, not a hypothetical.

This is the single most common pattern in AUSTRAC's own case files. In one documented example, a foreign national made an all-cash offer well above the asking price on a luxury apartment in Sydney's eastern suburbs. The agent didn't ask where the money came from. The funds turned out to come from multiple offshore accounts linked to a drug trafficking operation, and the property was later seized under proceeds-of-crime laws.²

A generous, fast, cash offer feels like a win. It's also exactly the profile criminals look for, because cash removes the paper trail a mortgage would create.

The Obiang case above is the clearest illustration of this. Nobody is saying a government minister can't be wealthy. But when someone's declared occupation, salary, or income doesn't remotely explain the money on the table, that gap is worth noting and asking about, not waving through.

In the Sydney case, funds moved through several offshore accounts, each linked to a different shell company registered in a tax haven.² Layering money through multiple entities is one of the oldest laundering techniques there is, precisely because it makes the original source harder to trace. If a buyer's deposit is arriving in pieces from several unrelated corporate accounts, that's worth understanding before you proceed, not after.

Part of how Obiang moved so much money into property was by acquiring assets in the United States and France through corporate entities and third parties, rather than ever putting his own name directly on the purchase.¹ Using a relative, associate or company as the name on a contract, while someone else entirely controls the money, is a recognised technique for putting distance between a person and an asset. It's called a nominee arrangement, and it's one of the reasons "who actually controls this purchase" is now a required question, not a polite one.

Zamira Hajiyeva became known in the UK press for spending £16 million at Harrods. Her husband, a former bank chairman, was sentenced to 15 years in prison for fraud and embezzlement. In 2018, the UK's National Crime Agency used its first ever Unexplained Wealth Order against her, targeting a mansion near Harrods and a golf course in Berkshire, both bought using funds she couldn't adequately explain.⁴ The Court of Appeal later upheld the order.

You don't need to recognise every foreign official. What you do need is a habit of asking where the money for a large purchase actually came from when the buyer holds, or is connected to, a position of public power.

This is the flip side of red flags 1 to 5, and it's the one your own profession needs to watch in itself. In Singapore's S$3 billion case, two real estate agents were fined in 2025 for failing to carry out basic customer due diligence on transactions connected to the case.⁵ Several law firms were penalised too, for inadequate scrutiny of clients and transactions they handled.⁶ Commissioner Austin Cullen, reflecting on BC's inquiry, put it plainly: it is "almost inevitable" that a lawyer will be involved at some stage when large sums, companies and property are in play.³ The professionals in these cases weren't accused of laundering money themselves. They were penalised for not asking, or not writing down that they'd asked.

One documented laundering technique flagged during the Cullen Commission involves a lawyer receiving funds into a trust account and then issuing a cheque to a third party, such as a property seller. To anyone examining the transaction later, the money simply appears to come from "Law Firm Trust Account," with the original source erased.³ If you're a conveyancer or solicitor, a trust account is a powerful tool, and also a laundering shortcut if the money going in isn't checked before it comes back out clean.

This applies directly to jewellers and precious metals dealers. Hong Kong now runs a dedicated registration and enforcement regime for dealers in precious metals and stones, specifically because gold and jewellery are so easy to convert into untraceable value.⁷ Hong Kong Customs regularly prosecutes small dealers for buying or selling goods worth more than HK$120,000 without registering under the scheme, and for failing to keep proper transaction records.⁸ If a customer's purchases seem deliberately sized to stay just under a threshold you know about, that's not a coincidence worth ignoring.

This is the most uncomfortable one, because it isn't about missing a red flag. It's about what happens after you've already spotted one. In the Singapore case, one law firm had filed a suspicious transaction report on a client, and then kept acting for that same client without properly documenting why it still considered that appropriate.⁶ Filing a report isn't the end of your obligation. What you do next, and whether you can show your reasoning, matters just as much.

Every case above shares a common texture: urgency, secrecy, and structures that only make sense if you don't ask questions. Regulators and inquiries across every FATF-aligned country, Australia, Singapore, the UK, Canada, Hong Kong, keep landing on the same underlying lesson. Criminals don't need every professional in a transaction to be complicit. They just need one who doesn't ask, or one who asks and doesn't listen to the answer.

None of the professionals named across these cases ran large, sophisticated compliance departments. Several were sole practitioners, small agencies, or small firms much closer in size to the businesses this newsletter is written for. The pattern in every one of these cases wasn't a failure of expertise. It was a failure of habit, not pausing to ask an obvious question when something didn't quite add up.

From 1 July 2026, under Tranche 2, that habit becomes a formal legal obligation in Australia. The next article in this series looks at exactly what to do once you do spot one of these red flags: when and how to file a Suspicious Matter Report, and how to keep acting professionally without either tipping off the client or exposing yourself to liability.

Next in this series: "Case Study: Suspicious Matter Reporting in Practice."