AML Compliance Guide

AML/CTF reporting obligations

Alongside your AML/CTF program and customer due diligence, reporting entities must recognise and act on three distinct triggers for reporting to AUSTRAC. This page covers what each one is, when it applies, and the deadline that runs once it's triggered.

Note: This is a summary of AUSTRAC guidance — not legal advice. Always read the source material and seek professional advice for your specific situation.

SMR

Suspicious Matter Report

When it applies

You have reasonable grounds to suspect a transaction or client is connected to proceeds of crime, money laundering, or terrorism financing.

Deadline

3 business days after forming the suspicion — or within 24 hours if terrorism financing is suspected. (AML/CTF Act 2006 (Cth) s 41)

  • Applies even if you decide not to file — AUSTRAC expects a documented reason for every assessment, not just every report.
  • Tipping off the client (or anyone connected to them) that a report has been filed or considered is a separate criminal offence.
  • A suspicion doesn't need to be proven — "reasonable grounds to suspect" is a lower bar than certainty.
Use the free SMR Decision Log →
TTR

Threshold Transaction Report

When it applies

You handle physical currency (cash) of $10,000 or more in a single transaction. Electronic transfers do not trigger a TTR — only cash.

Deadline

10 business days after the transaction. (AML/CTF Act 2006 (Cth) s 43)

  • Most relevant to businesses that accept large cash payments — some real estate agents, and any Tranche 2 firm handling cash settlements.
  • Deliberately splitting a transaction to stay under $10,000 (structuring) is itself a criminal offence, regardless of the source of funds.
Use the free TTR Log →
IFTI

International Funds Transfer Instruction

When it applies

You instruct or facilitate a transfer of money into or out of Australia on behalf of a client — wire transfers, international remittances.

Deadline

10 business days after the transfer. (AML/CTF Act 2006 (Cth) s 45)

  • Most relevant to remittance providers, and accountants or lawyers handling cross-border client transactions.
  • Less commonly triggered for Tranche 2 firms without international dealings, but still a mandated obligation where it applies.

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Building your program?

Reporting obligations are one of six minimum components an AML/CTF program must document.

AML/CTF program requirements →

Record keeping

Reporting decisions — filed or not — must be retained for at least 7 years alongside your other AML/CTF records.

Record keeping obligations →

Customer due diligence

A sanctions or PEP match during CDD is often the trigger that leads to an SMR assessment.

Customer due diligence →

Frequently asked questions

What are the AML/CTF reporting obligations for Tranche 2 businesses?
Every reporting entity must be ready to file three report types with AUSTRAC when triggered: a Suspicious Matter Report (SMR) when you have reasonable grounds to suspect money laundering or terrorism financing, a Threshold Transaction Report (TTR) for cash transactions of $10,000 or more, and an International Funds Transfer Instruction (IFTI) report for cross-border transfers you instruct on a client's behalf. Not every firm will trigger all three — a conveyancer who never handles cash, for example, may never need to file a TTR — but the obligation to recognise and act on a trigger applies to all reporting entities.
Do I need to file a report even if I decide a matter isn't suspicious?
You don't file an SMR for a matter you've assessed as not suspicious, but AUSTRAC expects you to be able to show your reasoning if asked. A documented decision log — recording what you considered and why you didn't file — is what protects you under audit. An undocumented "no" is indistinguishable from not having assessed it at all.
What happens if I miss a reporting deadline?
Late or missed SMRs, TTRs, and IFTIs are breaches of the AML/CTF Act 2006 (Cth) and can attract civil penalties. AUSTRAC has said its approach to Tranche 2 businesses during the transition period is supportive rather than punitive — but that support is for firms making genuine efforts, not for firms with no process to catch reportable events in the first place.
Can I tell a client that I've filed a suspicious matter report about them?
No. Tipping off — telling a client, or anyone connected to them, that an SMR has been filed or is being considered — is a criminal offence under the AML/CTF Act, separate from the reporting obligation itself. If a client asks directly whether you've reported them, you cannot confirm or deny it.
Does AML compliance software file these reports for me?
No software files an SMR, TTR, or IFTI automatically — forming the suspicion, or recognising a reportable cash transaction, is a human judgment made by your firm. What a structured log does is capture that judgment with a timestamp and reasoning at the time it was made, so the record exists whether or not a report is ultimately filed. See our free SMR Decision Log and TTR Log tools.

Based on the AML/CTF Act 2006 (Cth) and AUSTRAC's published reporting guidance, current as of the AML/CTF reforms that commenced 31 March 2026. Not legal advice. Verify current deadlines and thresholds on the AUSTRAC website.