Unexplained Wealth (Commonwealth Powers) Act 2021

Understanding the operation of this Act requires a precise examination of several core statutory definitions and mechanical concepts set out in section 3 and the newly inserted Division 3A of Part 7 of the Criminal Assets Confiscation Act 2005 (SA).

• Adoption 1 and Adoption 2: Section 4(1) adopts "National Unexplained Wealth Laws 1" and "National Unexplained Wealth Laws 2" of the Commonwealth. These terms refer directly to specific post-amended versions of the Proceeds of Crime Act 2002 (Cth) as defined in section 14C of that federal Act immediately before the South Australian Act received gubernatorial assent. This dual-adoption structure separates the initial baseline adoption of federal law from subsequent legislative modifications, allowing South Australia to maintain distinct control over which iterations of federal law apply within its borders.
• Amendment Reference: Under section 5(1), South Australia refers to the Commonwealth Parliament the power to make express amendments to the Proceeds of Crime Act 2002 (Cth) concerning "unexplained wealth" and "information gathering." However, this reference is strictly confined by section 5(2), which excludes any power to allow the restraint, forfeiture, seizure, or forced payment of property "otherwise than by order of a court."
• Unexplained Wealth and Wealth: Unexplained wealth is defined as "property or wealth that might not have been lawfully acquired." This definition is notable for its speculative statutory threshold: the use of the term "might not" represents a low evidentiary bar that differs significantly from standard civil standards of proof, such as the balance of probabilities, or criminal standards of proof beyond reasonable doubt. The terms "wealth," "property," and "lawfully acquired" are locked to the meanings they held in the federal Proceeds of Crime Act 2002 immediately before the enactment of the Unexplained Wealth (Commonwealth Powers) Act 2018 of New South Wales, preventing subsequent federal amendments from unilaterally expanding the definitions without South Australian consent.
• Information Gathering: This is defined under section 3 as the production or provision of information for the purposes of, or relevant to, taking action or instituting proceedings under a state law. Under the referral, federal information-gathering mechanisms (such as production orders, search warrants, and monitoring orders) are made available to support state-level asset recovery actions.
• Shareable Forfeiture Proceeds and Net Amount: Under section 209B, forfeiture proceeds are "shareable" if they are "corresponding proceeds" of the State and exceed the "NSC threshold" defined in the NCSUW agreement. The "net amount" represents these shareable proceeds after deducting any court-ordered payments to third parties and any specific contributions payable to foreign jurisdictions under section 209E.
• Cooperating Jurisdiction Committee (CJC) and CJC Subcommittee: The CJC is the intergovernmental body established under the NCSUW agreement. When South Australia recovers shareable proceeds, a specific CJC subcommittee must be formed under section 209G, consisting of South Australia and any other jurisdiction determined by unanimous vote to have made a material contribution to the recovery of those assets.

---

The Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) directly affects a broad array of public, private, domestic, and international actors, shifting their legal rights, fiscal incentives, and operational obligations.

• Suspected Individuals and Property Holders: The primary target group consists of individuals suspected of involvement in serious or organised crime, as well as any third parties who hold property on their behalf. Because "unexplained wealth" is defined speculative-style as property that "might not have been lawfully acquired," the Act affects anyone who cannot produce an audit trail of lawful acquisition for their accumulated assets. The practical burden shifts to the asset holder to disprove the assumption of unlawful acquisition once the statutory triggers under the federal Act are met.
• State Law Enforcement and Prosecutorial Agencies: The South Australian Police (SAPOL) and the Director of Public Prosecutions (DPP) are directly affected. They gain the ability to collaborate with federal agencies, such as the Australian Federal Police (AFP) and the Australian Criminal Intelligence Commission (ACIC), using federal information-gathering powers. However, this collaboration comes with administrative costs, including strict notification timelines and participation in complex multilateral committee processes.
• The South Australian Executive (The Minister and Attorney-General): The Minister (typically the Attorney-General) is burdened with strict administrative duties, such as the mandatory 60-day notification requirement under section 209D. The Attorney-General is also responsible for executing payments to other jurisdictions within the prescribed payment periods under section 209J.
• Other Australian States and Territories: Under the cooperative scheme, both "participating States" (those that have adopted the federal laws) and "non-participating States" (which may still have contributed to an investigation) are affected. The Act establishes mechanisms to pay contributing non-participating states (section 209H) and to split remaining net amounts among participating subcommittee members (section 209I).
• Foreign Jurisdictions: International law enforcement and sovereign states that assist in asset tracing are affected. Under section 209E, if the Minister decides a foreign jurisdiction contributed to the recovery of shareable proceeds, a specified amount becomes legally payable to that foreign power, bypassing standard domestic consolidated revenue paths.
• Beneficiaries of State Funds: The Victims of Crime Fund and the Justice Rehabilitation Fund are direct fiscal beneficiaries. Under section 209K, South Australia’s final share of recovered proceeds must be paid into the Victims of Crime Fund, or, if the proceeds relate to a "prescribed drug offender," into the Justice Rehabilitation Fund. Conversely, these funds bear the opportunity cost of sharing proceeds with other jurisdictions that might previously have been kept entirely within the state.

---

The Act establishes a complex network of statutory duties, limitations on executive action, and constitutional rights designed to manage the transfer of state power to the Commonwealth.

Executive and Ministerial Duties

The Minister is subject to a strict statutory duty under section 209D(1). Within 60 days of a final order, negotiated settlement, or other forfeiture occurring under a "relevant law" where the proceeds exceed the NSC threshold, the Minister must notify the Cooperating Jurisdiction Committee in writing. This notification is not discretionary. Under section 209D(2), the notice must contain sufficient information to allow other jurisdictions to determine if they have a viable claim of "contribution" in relation to those proceeds.

Once the CJC subcommittee has determined the allocation of the "net amount," the Attorney-General is subject to a mandatory duty under section 209J to pay the agreed proportions to the Commonwealth, other States, or Territories. This payment must occur within the specific payment period defined in the NCSUW agreement or prescribed by local regulations.

The Right to Roll Back Federal Amendments

To guard against federal legislative encroachment, the South Australian executive retains a specific right under section 7 of the Act. If the Commonwealth Parliament enacts an express amendment to the Proceeds of Crime Act 2002 (Cth) that South Australia finds unacceptable, the Governor may, by proclamation, declare that the amendment does not apply to proceedings, applications, orders, or notices within South Australia. For this rollback right to be legally effective, the Governor’s proclamation must come into force within six months of the enactment of the federal amendment.

The Right of Unilateral Termination

The State retains the ultimate right to terminate both its statutory adoptions and its legislative reference. Under section 9(1), the Governor may at any time, by proclamation, terminate Adoption 1, Adoption 2, or the amendment reference.

Furthermore, section 10 establishes a right of immediate termination in specific circumstances. If the Commonwealth Parliament enacts an express amendment that is "inconsistent with the fundamental attributes of the unexplained wealth provisions" (defined under section 10(2) as any amendment allowing restraining, payment, seizure, or forfeiture orders to be made otherwise than by a court), the Governor may terminate the referral. Similarly, under section 10(3), if the Commonwealth amends its own rollback provisions (sections 14G or 14J) or its international asset-sharing divisions (Part 4-3 Division 2), South Australia reserves the right to terminate its participation.

---

While the Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) does not contain a schedule of direct criminal penalties (such as terms of imprisonment or statutory fines) within its own text, it acts as a direct procedural conduit for severe economic and civil penalties. It does this by linking specific South Australian offences to the federal asset confiscation regime.

Triggering Offences under Section 8

The Act specifies which South Australian offences are "relevant offences" for the purposes of invoking the Commonwealth's unexplained wealth powers. Under section 8, these offences include:

• Any indictable offence against a law of South Australia.
• An offence against section 68(3) of the Criminal Law Consolidation Act 1935 (which relates to blackmail and demanding property with menaces).
• Offences against sections 52, 53, 72, or 74 of the Fisheries Management Act 2007 (relating to commercial fishing violations, unlawful possession, and trafficking in commercial quantities of fish).
• An offence against section 99 of the Liquor Licensing Act 1997 (which relates to the unauthorised sale or consumption of liquor on unlicensed premises).
• Any offence against the Lottery and Gaming Act 1936.
• Offences against sections 47, 48, 48A, 51, or 60 of the National Parks and Wildlife Act 1972 (which relate to the illegal taking, keeping, or selling of protected animals and native plants).
• Offences against sections 28(1)(a) or 41 of the Summary Offences Act 1953 (which relate to possession of offensive weapons or unlawful possession of property).

By defining these regulatory and summary offences as "relevant offences," the Act permits federal authorities to initiate unexplained wealth investigations even where the underlying state offence is not an indictable crime.

Enforcement via the NCSUW Scheme

Once a relevant offence triggers an investigation, the state’s asset recovery mechanisms are executed under the "relevant laws" defined in section 209B. These laws include:

• Forfeiture orders (under section 47 of the Criminal Assets Confiscation Act 2005).
• Deemed forfeiture orders (under section 56A).
• Pecuniary penalty orders (under section 95).
• Literary proceeds orders (under section 111, which confiscate profits made from commercialising criminal exploits).
• Unexplained wealth orders (under section 9 of the Serious and Organised Crime (Unexplained Wealth) Act 2009).

The enforcement is purely economic: the forced liquidation of property, the freezing of bank accounts, and the registration of charges over real estate. The enforcement burden is altered because the Commonwealth POCA framework allows for the restraining of assets on a reasonable suspicion that a person's total wealth exceeds their lawfully acquired wealth, forcing the respondent to litigate to protect their assets.

---

The Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) is a complex piece of referral legislation that sits at the intersection of constitutional, federal, and state laws.

┌────────────────────────────────────────────────────────────────────────┐
│                        AUSTRALIAN CONSTITUTION                         │
│                           Section 51(xxxvii)                           │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │ References power / Adopts laws
                                    ▼
┌────────────────────────────────────────────────────────────────────────┐
│             Unexplained Wealth (Commonwealth Powers) Act 2021           │
└───────────────────────┬────────────────────────┬───────────────────────┘
                        │                        │
     Amends and Links   │                        │ Integrates with
                        ▼                        ▼
┌──────────────────────────────────────┐  ┌──────────────────────────────┐
│  Criminal Assets Confiscation Act   │  │  Proceeds of Crime Act 2002  │
│              2005 (SA)               │  │            (Cth)             │
│   • Inserts Part 7 Division 3A       │  │  • Applies ss 14C, 14F, 14G, │
│     (National Cooperative Scheme)    │  │    14J, 20A, and Part 2-6    │
│   • Diverts Victim of Crime /        │  └──────────────┬───────────────┘
│     Justice Rehab Funds              │                 │
└───────────────────┬──────────────────┘                 │ Applies to SA Offences
                    │                                    ▼
                    │                     ┌──────────────────────────────┐
                    │                     │   SA Triggering Statutes     │
                    │                     │   • Criminal Law Consolidation  │
                    │                     │     Act 1935 (s 68(3))       │
                    │                     │   • Fisheries Management Act │
                    │                     │     2007 (ss 52, 53, 72, 74) │
                    │                     │   • Liquor Licensing Act     │
                    │                     │     1997 (s 99)              │
                    │                     │   • National Parks and       │
                    └────────────────────►│     Wildlife Act 1972        │
                                          │     (ss 47, 48, 48A, 51, 60) │
                                          │   • Summary Offences Act     │
                                          │     1953 (ss 28(1)(a), 41)   │
                                          └──────────────────────────────┘

Constitutional Interaction

The Act relies on section 51(xxxvii) of the Constitution of the Commonwealth, which allows state parliaments to refer matters to the Commonwealth Parliament, or to adopt Commonwealth laws that have already been enacted. This interaction is designed to overcome the constitutional limitations of the "split" jurisdiction between state and federal asset-forfeiture regimes.

Interaction with Commonwealth Statutes

The Act directly integrates with the Proceeds of Crime Act 2002 (Cth). It refers power specifically in relation to:

• Section 20A of the Cth Act (which governs the making of unexplained wealth orders).
• Part 2-6 of the Cth Act (the operational core of the federal unexplained wealth regime).
• Section 14F (defining cooperating states), section 14G (rollback of amendments in relation to proceedings), and section 14J (rollback of amendments in relation to applications, orders, and notices).
• Section 338 (defining non-participating states).

This referral ensures that when federal authorities seek unexplained wealth orders against South Australian residents or assets, they are not acting outside their constitutional jurisdiction.

Interaction with South Australian Statutes

The Act modifies two primary state statutes via Schedule 1:

1. Criminal Assets Confiscation Act 2005 (SA): The Act inserts a new Division 3A into Part 7. This insertion fundamentally alters section 209 (Credits to Victims of Crime Fund) and section 209A (Credits to Justice Rehabilitation Fund). It carves out any "shareable forfeiture proceeds" from the state's unilateral control, routing them instead through the cooperative distribution rules of the CJC subcommittee. It also explicitly amends the definition of "equitable sharing program" under section 209(4) to state that it does not include the national cooperative scheme, thereby preventing the dual-application of state and federal sharing rules to the same asset pool.
2. Serious and Organised Crime (Unexplained Wealth) Act 2009 (SA): The Act amends section 45 of this statute, ensuring that any money recovered by the Crown under an unexplained wealth order that qualifies as "shareable forfeiture proceeds" under the Criminal Assets Confiscation Act 2005 must be dealt with according to the newly inserted Division 3A rather than being directly deposited into state funds.

The Act also explicitly disapplies section 7(5) of the Acts Interpretation Act 1915 (SA) under its commencement provisions (section 2(2)), meaning that standard interpretive rules regarding the survival of rights, privileges, or liabilities upon amendment or repeal do not apply, giving the state's executive clean-break capability if they choose to terminate the referral.

---

Since its passage, the Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) has had a stable but evolving legislative history.

Principal Act Enactment

The principal Act was passed by the Parliament of South Australia as Act No. 27 of 2021.

• Assent Date: 1 July 2021.
• Commencement Date: 1 September 2021 (notified via the South Australian Government Gazette on 18 August 2021, page 3099).

The enactment was timed to align South Australia with the national cooperative framework, following similar legislative referrals by other jurisdictions (for example, New South Wales passed its referral legislation in 2018, which is referenced in section 3 of the South Australian Act to lock in baseline definitions of "lawfully acquired," "property," and "wealth").

Subsequent Amendments

While the core text of the Unexplained Wealth (Commonwealth Powers) Act 2021 has remained largely unamended since its commencement, it is subject to pending legislative integration:

• Biodiversity Act 2025 (SA): Enacted as Act No. 29 of 2025, assented to on 26 June 2025. Schedule 5, clause 99 of this Act contains uncommenced amendments to the Unexplained Wealth (Commonwealth Powers) Act 2021. Once commenced, these amendments are designed to integrate new biodiversity-related conservation offences into the asset-forfeiture regime, reflecting a policy expansion that allows the state to target the financial proceeds of environmental crimes using the same federal unexplained wealth mechanisms.

---

The source text of the Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) does not cite or name any specific judicial decisions or decided cases.

While the statutory text does not record any completed litigation, the constitutional and procedural architecture of the Act is designed to anticipate and withstand specific litigation risks. Because the referral of power under section 51(xxxvii) of the Constitution is a high-stakes legislative transfer, the drafting of the Act reflects a protective stance against potential litigation:

1. Jurisdictional and Constitutional Validity Challenges: Under section 5(3), the reference of matters to the Commonwealth has effect only if and to the extent that the matter is not already within the legislative powers of the Commonwealth, and only if it is within the legislative powers of the South Australian Parliament. This dual-precondition is designed to insulate the referral from constitutional challenges by defendants who might argue that the Commonwealth has exceeded its legislative power, or that the State has attempted to refer a power it did not possess.
2. Strict Preservation of Judicial Power to Preempt Chapter III Challenges: Under the Commonwealth Constitution, Chapter III courts must not be given administrative or non-judicial tasks that are incompatible with their judicial character. Section 5(2) and section 10(2) of the Act explicitly exclude any power to allow administrative (non-court ordered) restraint, seizure, or forfeiture of assets. By ensuring that only a court can make these orders, the Act aims to prevent litigation that could invalidate unexplained wealth actions on the grounds of constitutional incompatibility or breach of the separation of powers.
3. Disputes Over Unanimous Decisions within the CJC Subcommittee: Under section 209H and section 209I(2), the distribution of the "net amount" of shareable proceeds to non-participating states or via unequal divisions depends on a "unanimous decision" of the CJC subcommittee. If a contributing state disagrees with a decision, the lack of unanimity forces a reversion to the default equal-split rule under section 209I(1). While this avoids court litigation between governments by utilizing an administrative committee, it introduces a significant risk of inter-jurisdictional dispute if a state feels its investigative contribution has been undervalued.

---

The Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) contains several operational "gotchas",statutory traps, counter-intuitive rules, and hidden burdens,that present significant risks for legal practitioners, commercial operators, and state administrators.

1. The Speculative Threshold for "Unexplained Wealth"

Under section 3, unexplained wealth is defined as property or wealth that "might not have been lawfully acquired." The use of "might not" creates a highly speculative, subjective trigger. Unlike standard civil asset confiscation regimes that require the state to prove a connection to a specific unlawful act on the balance of probabilities, this definition allows investigations to commence based on a suspicion of a mismatch between an individual's asset portfolio and their declared taxable income. This places a reverse onus of proof on the respondent, who must then trace and document the origin of their assets to avoid forfeiture.

2. The Strict Six-Month Rollback Window

Under section 7, if the Commonwealth Parliament amends the Proceeds of Crime Act 2002 (Cth) in a way that disadvantages South Australia, the Governor's power to issue a "rollback" proclamation is highly time-sensitive. To be legally effective under the federal Act, the proclamation must come into force within 6 months of the federal amendment's enactment. This represents a narrow operational window. If the state bureaucracy fails to identify an adverse federal amendment, draft the proclamation, obtain executive council approval, and publish it in the Gazette within 180 days, the state loses its right to prevent the federal amendment from applying to local proceedings.

3. Inclusion of Minor and Regulatory Offences

While unexplained wealth legislation is often publicised as a tool targeting high-level organised crime figures (such as drug cartels or human traffickers), the list of "relevant offences" under section 8 includes minor, regulatory, and summary offences:

• Section 99 of the Liquor Licensing Act 1997 (selling or consuming liquor on unlicensed premises).
• Sections 52, 53, 72, and 74 of the Fisheries Management Act 2007 (which can include possession of commercial quantities of fish without appropriate licensing).
• Section 28(1)(a) of the Summary Offences Act 1953 (possession of an offensive weapon).

Consequently, an individual or small business owner involved in a commercial fishing dispute or an unauthorised liquor sale could find their entire commercial asset portfolio subjected to a federal "unexplained wealth" investigation.

4. Loss of Local Control over Asset Sharing

Once South Australian law enforcement assets are classified as "shareable forfeiture proceeds" under section 209B, the state's default "equitable sharing program" is explicitly turned off (section 209(4)). The state can no longer unilaterally decide how to distribute these funds. Instead, they are locked into the CJC subcommittee process under section 209G. If the subcommittee cannot reach a unanimous decision regarding a contribution by a non-participating state under section 209H, or an unequal division under section 209I(2), the default rule under section 209I(1) applies, forcing an equal split between South Australia and all other contributing jurisdictions represented on the subcommittee, regardless of which state did the majority of the investigative work.

┌────────────────────────────────────────────────────────────────────────┐
│                        RECOVERED SHAREABLE PROCEEDS                    │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │
                                    ▼
                      Is there a unanimous decision 
                      on unequal division (s 209I(2))?
                                    │
                  ┌─────────────────┴─────────────────┐
               NO │                                   │ YES
                  ▼                                   ▼
┌─────────────────────────────────────┐ ┌─────────────────────────────────────┐
│          DEFAULT SPLIT              │ │          UNANIMOUS AGREEMENT        │
│  Proceeds split EQUALLY between SA  │ │  Proceeds paid in the SPECIFIED     │
│  and ALL contributing jurisdictions │ │  PROPORTIONS agreed by the          │
│  on the CJC subcommittee.           │ │  subcommittee.                      │
└─────────────────────────────────────┘ └─────────────────────────────────────┘

5. Disapplication of the Acts Interpretation Act

Under section 2(2), section 7(5) of the Acts Interpretation Act 1915 (SA) is explicitly excluded. This means that if South Australia decides to terminate its adoption or reference of powers, the standard statutory protections that preserve accrued rights, investigation liabilities, or ongoing legal proceedings upon the expiration of an Act are bypassed. This creates a risk of legal vacuums or abrupt terminations of ongoing asset-recovery proceedings.

---

Compliance with the Unexplained Wealth (Commonwealth Powers) Act 2021 (SA) requires different strategies depending on whether the stakeholder is a state administrative agency or a private party.

Compliance for State Government Agencies and Officials

┌────────────────────────────────────────────────────────────────────────┐
│                      STATE AGENCY COMPLIANCE TIMELINE                  │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │
                                    ▼
┌────────────────────────────────────────────────────────────────────────┐
│  STEP 1: Identify "Shareable Proceeds" (> NSC Threshold)               │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │
                                    ▼ Within 60 Days (s 209D)
┌────────────────────────────────────────────────────────────────────────┐
│  STEP 2: Notify Cooperating Jurisdiction Committee in Writing           │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │
                                    ▼ During Decision-Making Period
┌────────────────────────────────────────────────────────────────────────┐
│  STEP 3: Convene CJC Subcommittee & Determine Net Amount (s 209F-I)    │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │
                                    ▼ Within Prescribed Payment Period (s 209J)
┌────────────────────────────────────────────────────────────────────────┐
│  STEP 4: Pay Agreed Proportions to Contributing Jurisdictions          │
└───────────────────────────────────┬────────────────────────────────────┘
                                    │
                                    ▼ Remaining Balance
┌────────────────────────────────────────────────────────────────────────┐
│  STEP 5: Deposit SA Share into Victims of Crime/Justice Rehab Fund     │
└────────────────────────────────────────────────────────────────────────┘

1. Adherence to the 60-Day Notification Window: The Minister and departmental administrators must establish compliance systems to flag any final order, negotiated settlement, or forfeiture under a "relevant law" that exceeds the NSC threshold. Once identified, written notice must be delivered to the Cooperating Jurisdiction Committee within 60 days of the triggering event (section 209D(1)). The notice must contain detailed technical contribution data to satisfy section 209D(2).
2. Subcommittee Formation and Documenting Unanimous Decisions: The state’s representative on the Cooperating Jurisdiction Committee must ensure that a CJC subcommittee is formed under section 209G for every shareable net amount. To protect the state's financial interests, any distribution of funds to non-participating states under section 209H, or any unequal distribution under section 209I(2), must be backed by a written, unanimous decision executed within the specified "decision-making period."
3. Executing Timely Payments: The Attorney-General’s Department must track the payment timelines specified in the NCSUW agreement. Under section 209J, any funds owed to the Commonwealth, other States, or Territories must be paid within the prescribed payment period to prevent breach of the intergovernmental agreement.
4. Accurate Fund Allocation: Internal accounting systems must correctly route remaining state funds under section 209K. Standard proceeds must be paid into the Victims of Crime Fund, whereas proceeds derived from a "prescribed drug offender" must be directed to the Justice Rehabilitation Fund.

Compliance for Private Parties and Professional Advisors

1. Maintain Comprehensive Wealth Audit Trails: For high-net-worth individuals, commercial operators in regulated industries (such as fisheries or liquor), and their professional advisors (accountants, tax agents, and lawyers), the speculative "might not have been lawfully acquired" standard requires meticulous record-keeping. Compliance means maintaining a clear audit trail for all asset acquisitions, including:
   • Tax returns and notices of assessment.
   • Bank statements showing the clear path of funds for property deposits.
   • Executed loan agreements, mortgages, and records of interest payments.
   • Wills, probate documents, and statutory declarations confirming any inherited wealth or monetary gifts.
2. Advise on Cross-Jurisdictional Risks: Legal practitioners advising clients facing state-based regulatory investigations (e.g., under the Fisheries Management Act 2007 or Liquor Licensing Act 1997) must warn clients that these state offences are "relevant offences" under section 8. Consequently, a localized regulatory breach can trigger a broader, federal-level unexplained wealth investigation under the Proceeds of Crime Act 2002 (Cth), exposing their entire asset portfolio to federal restraint and forfeiture proceedings.