A tax haven is a risk factor, not a country list you invent

You will be asked to name “the tax havens” as if a blog could settle the list. It cannot. Checked against AUSTRAC's high-risk countries, regions and groups page on 14 October 2026. This is general information, not legal advice. This page does not reproduce that guidance, and it names no country. Who you still have to see through the structure is a beneficial owner. A different cross-border risk, weapons and sanctions, is proliferation financing. The sector map is /tranche-2.

What the phrase is doing on an AML file

AUSTRAC's high-risk countries page treats a known tax haven as one reason a place can be higher risk, alongside a FATF high-risk or non-cooperative finding, a prescribed foreign country, sanctions, and support for terrorist organisations. Those are not one list. On the tax-haven point, AUSTRAC describes places with minimal tax for non-residents that do not share financial or banking information with foreign tax authorities. It says criminals can use that secrecy to conceal income and evade tax, and it expects you to notice unusual transactions, including multiple international transfers to or from a place you treat as a known tax haven. A suspicion of tax evasion can be reported. Secrecy is also why the same structures show up in laundering: they make it harder to see whose money it is.

That is a risk judgment inside your program, made against the current official material, not against a nickname in a headline. A newspaper label is not the FATF call. If your office keeps a private schedule of forbidden countries, replace it with a habit of opening the current FATF public statements and AUSTRAC's page on the day you assess the customer.

The FATF call is a narrower rule

Enhanced customer due diligence has its own trigger. AUSTRAC's reform guidance says you must apply it when the customer, a beneficial owner, a person the designated service is for, or a person acting for the customer is physically present in, or formed in, a jurisdiction where the FATF has called for enhanced due diligence. Read the current FATF statement on jurisdictions subject to a call for action, and the separate statement on jurisdictions under increased monitoring. AUSTRAC also expects Australian sanctions to feed your country risk. A place you worry is a tax haven is not automatically that FATF call. Do not upgrade every foreign company into enhanced due diligence because the word offshore appeared in an email, and do not skip the FATF call because the country was missing from a blog.

You still look through to a person

• Ownership or control. An individual who owns 25% or more of the customer, or who controls the customer, is the person you are trying to see. A secrecy structure does not delete that test.
• Source of funds. Where the value came from, and whether that story matches the service you are being asked to provide.
• Why this place? A connection to a low-transparency jurisdiction needs a reason you can record. The absence of a reason is the flag, not the foreignness.
• Sanctions are separate. Screening against the DFAT consolidated list is not the same job as a tax-haven concern. Proliferation financing is a further, different risk.
• Do not tip the client off. You can ask for the chart and the source of funds. You do not announce that you might report them.

From 1 July 2026 the new designated services can put this on a professional file: a client asks you to form, hold, or move value through an entity whose ownership you cannot see, with a connection to a place your program rates as higher risk. That is a customer and service question. It is not automatically a suspicious matter report, and it is not automatically fine. You suspect on reasonable grounds, or you do not. The reporting clocks AUSTRAC publishes are 24 hours for terrorism financing and 3 business days after the day you form other suspicions, which can include a tax offence. Enrolment, if you provide a designated service, is on AUSTRAC Online. FreeAML does not enrol you and does not lodge the report.

Where this page stops

This page is the risk factor and the look-through. A sector-neutral pause before you get to countries is money-laundering red flags for a small business. How crime money is taught in stages is placement, layering and integration.

What your client pays

On FreeAML you pay $0 for the suite. You email your client a link. Verification is client-pays. On the public list a personal KYC check is $20 and a company or trust KYB check is $40. There is no subscription. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a country is a tax haven, and it does not replace the beneficial-owner test.

Frequently Asked Questions