SMR and TTR Reporting: When and How to Report to AUSTRAC

From 1 July 2026, accounting firms providing designated services must comply with AUSTRAC's mandatory reporting obligations. Missing a reporting deadline — or failing to report when required — is a civil contravention of the AML/CTF Act that can attract significant penalties.

This guide explains the two main reporting obligations: Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) — what triggers each, the relevant deadlines, and how to lodge them correctly.

Suspicious Matter Reports (SMRs)

What Triggers an SMR?

An SMR must be lodged whenever a reporting entity suspects, on reasonable grounds, that a transaction or attempted transaction may be related to:

• Money laundering or terrorism financing
• Tax evasion or avoidance of a taxation reporting obligation
• Proceeds of crime (any serious offence)
• An attempt to avoid triggering a reporting obligation (structuring)

The obligation arises from suspicion, not certainty. You do not need evidence or proof — reasonable suspicion based on the facts available to you is sufficient. Common red flags in accounting engagements include unexplained wealth, unusual transaction structures, reluctance to provide identity documentation, and inconsistencies between declared income and lifestyle.

SMR Deadlines

The clock starts when the suspicion arises, not when the transaction occurs. If you discover concerning information during a client review rather than at the time of a transaction, the deadline runs from the point of discovery.

The Tipping-Off Prohibition

Once you have formed a suspicion or lodged an SMR, you must not disclose this to the client or any third party. The tipping-off prohibition is a criminal offence under the AML/CTF Act — this includes direct disclosure, hints, changed behaviour toward the client, or any action that could alert them to the report. All staff must be trained on this requirement.

Threshold Transaction Reports (TTRs)

What Triggers a TTR?

A TTR is required for any physical cash transaction of AUD 10,000 or more(including foreign currency equivalent). "Physical cash" means Australian or foreign notes and coins. Electronic transfers, cheques, and EFTPOS transactions do not trigger a TTR requirement — only transactions involving physical currency.

Structuring — deliberately splitting a transaction into amounts below AUD 10,000 to avoid a TTR — is itself an offence under the AML/CTF Act, and any pattern of near-threshold cash transactions should be considered a red flag requiring an SMR.

TTR Deadline

TTRs must be lodged within 10 business days of the transaction. Unlike SMRs, there is no discretion — if the threshold is met, the report is mandatory regardless of whether the transaction appears suspicious.

How to Lodge Reports with AUSTRAC

1. Log into AUSTRAC Online using your reporting entity credentials.
2. Select the report type — SMR or TTR — from the reporting menu.
3. Complete all required fields. For SMRs: describe the suspicious matter in detail, including the facts and circumstances that gave rise to the suspicion. Be factual, specific, and thorough — vague reports are less actionable for AUSTRAC investigators.
4. Attach any supporting documents if relevant (transaction records, identity documents, correspondence).
5. Submit and retain confirmation. AUSTRAC will issue a report reference number. Keep this in your compliance records for 7 years.

Most compliance platforms — including Clear AML — provide pre-built SMR and TTR workflows that generate the report in the correct AUSTRAC format and submit directly via the AUSTRAC reporting API, removing the manual steps above.