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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, or
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Within three business days for other matters.
From 1 July 2026, AUSTRAC will introduce an updated reporting form that collects more detailed information about clients, entities and transactions, including digital and virtual assets.
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.
Under the upcoming reforms, AUSTRAC will require additional information in the TTR form, and existing reporting entities will have until March 2029 to move across to the new reporting format.
How do I report to AUSTRAC?
Reports are lodged securely through your AUSTRAC Online account.
The process involves selecting the type of report (SMR or TTR), entering the client and transaction details, and submitting within the required timeframe.
Once the Tranche 2 reforms take effect, you’ll use an enhanced online reporting form that captures more detailed data, including about beneficial owners and transaction channels.
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.
Under the new framework, AUSTRAC will place a stronger focus on data quality and record-keeping, so maintaining complete and accurate information will be key.
Will my client know if I file a report with AUSTRAC?
No. You must not tell or hint to your client that you’ve filed a report or that you suspect them. This is called “tipping off”, and it’s an offence under the AML/CTF Act.
All reporting should remain confidential within your firm’s compliance framework.
Don’t make any reference to it within the clients matter file in case they ask for a copy of the file. This can easily happen where your case management system is set up to file emails onto it. We recommend any reports or conversations around them are completely separate to the case management system.