Suspicious matter reports (SMRs)
Due within three business days of forming a suspicion on reasonable grounds that a matter may involve money laundering, terrorism financing, proceeds of crime or tax evasion, or that a customer is not who they claim to be. Within 24 hours if terrorism financing is suspected. You do not need proof; you need a reasonable suspicion. Record the suspicion internally the day it forms, lodge through AUSTRAC Online, reassess the client's risk, and keep the record for seven years.
Threshold transaction reports (TTRs)
Due within ten business days of receiving or paying physical currency of AU$10,000 or more (or the foreign equivalent) as part of a designated service. Transfers, cheques and cards do not count. Several smaller cash payments that seem designed to stay under the threshold are not a TTR, but they are a classic reason for an SMR. Many small firms simply do not accept cash at that level and say so in their program.
Transaction monitoring
Banks run automated transaction monitoring systems over millions of transactions. For a small professional firm the obligation is proportionate: compare what the client does with the purpose they stated, notice what does not fit and escalate it. A written procedure and a record of reviews is what AUSTRAC expects, not software built for a bank.
International funds transfer instructions (IFTIs)
Entities that send or receive instructions to transfer money into or out of Australia, chiefly banks and remitters, report each within ten business days. Most Tranche 2 firms do not send IFTIs themselves; their bank does.
The annual compliance report
A yearly questionnaire on your program, compliance officer, due diligence, reports lodged and training, covering the previous calendar year and lodged in the first quarter of the next. It is not an audit, but it asks for numbers you will only have if you kept records.
Tipping off
Do not disclose that an SMR has been made or is being considered, or information from which that could be inferred, where doing so could reasonably be expected to prejudice an investigation. The reformed offence (from 31 March 2026) focuses on that harm rather than banning all disclosure, but the safe practice in a small firm is unchanged: discuss it only with your compliance officer and AUSTRAC.
Questions people ask
- What counts as a business day?
- Monday to Friday, excluding national public holidays. Three business days from a Thursday suspicion is the following Tuesday.
- Do I have to stop acting for a client after an SMR?
- Not by itself. You must report, reassess the risk and keep watching. Whether to continue is a separate decision under your program.
- Is reporting in good faith protected?
- Yes. A report made in good faith is protected from civil, criminal and administrative liability, and does not breach professional confidentiality obligations.
General information about Australian AML/CTF law, not legal advice. The Act, the Rules and AUSTRAC's guidance are the primary sources.