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FAQs - AML Reporting Obligations
What is a Suspicious Matter Report (SMR)?
An SMR is a report you must submit to AUSTRAC when you have reasonable grounds to suspect that a client, transaction or proposed transaction may be linked to money laundering, terrorism financing, tax evasion, or other criminal activity.
You don’t need proof, reasonable suspicion is enough. SMRs help AUSTRAC and law enforcement identify and disrupt criminal activity. When it comes to AUSTRAC’s definition of reasonable, they say: “after considering all the information and circumstances available, a reasonable person would conclude that there is a relevant suspicion and an SMR should be submitted.”
You must lodge an SMR:
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Within 24 hours if the suspicion relates to terrorism financing.
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Within 3 business days for all other suspicions.
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If the SMR includes information protected by legal professional privilege (LPP), the AMLCO has up to 5 business days after forming the suspicion to submit the SMR to AUSTRAC. This includes situations where part of the information is privileged and belongs to someone other than the reporting entity. This extended timeframe does not apply where the suspicion relates to terrorism financing.
What is a Threshold Transaction Report (TTR)?
A TTR is a report you must file when a client makes a cash transaction of AUD 10,000 or more (or the foreign currency equivalent) in physical bank notes or coins.
These reports help track large cash movements that could be used to hide criminal funds. Currently, TTRs must be submitted within 10 business days of the transaction.
How do I report to AUSTRAC?
Reports are submitted through AUSTRAC online using the applicable reporting forms and within the required reporting timeframes.
The process involves selecting the type of report (SMR or TTR), entering the client and transaction details, and submitting within the required timeframe.
What happens after I lodge a report with AUSTRAC?
After you submit an SMR or TTR, AUSTRAC reviews the data and may share it with law enforcement agencies. You won’t always hear back from them. Your obligation is simply to report in good faith and keep proper records.
You must keep copies of the report and your supporting notes for seven years.
AUSTRAC places significant importance on data quality, record-keeping and timely reporting, so maintaining complete and accurate information is an important part of meeting your AML/CTF obligations.