From 1 July 2026, Australian professional services firms providing designated services must comply with AUSTRAC's mandatory reporting obligations. There are two main reports: Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs). 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 what triggers each report, the relevant deadlines, and exactly how to lodge them correctly.
Part 1 — Suspicious Matter Reports (SMRs)
When must you lodge an SMR?
You must lodge an SMR with AUSTRAC whenever you suspect — on reasonable grounds — that a transaction or matter may relate to:
- Money laundering or proceeds of crime
- Financing of terrorism
- Tax evasion or a tax offence
- Any other serious criminal offence under Australian law
The key word is "suspect" — not "know." You do not need evidence or proof. Reasonable suspicion based on the circumstances available to you is sufficient — and required. If you would genuinely wonder whether a matter might be connected to crime, you likely need to lodge an SMR.
SMR deadlines
The timing of your SMR matters:
- Terrorism financing suspicions: As soon as practicable, and no later than 24 hours after forming the suspicion
- All other suspicious matters: As soon as practicable after forming the suspicion — AUSTRAC doesn't set a specific number of days, but prompt reporting is expected
What counts as "suspicious" for Tranche 2 reporting entities?
Common red flags in accounting engagements that may trigger an SMR obligation:
- Unexplained wealth or assets inconsistent with declared income
- Unusual corporate structures with no apparent commercial purpose
- Requests to set up nominee arrangements to conceal beneficial ownership
- Cash payments or requests to structure transactions in unusual ways
- Clients who are reluctant to provide identity information or give inconsistent answers
- Transactions involving jurisdictions known for money laundering or tax evasion
- A client's business activities appear inconsistent with their transaction volumes
Tipping off is a criminal offence. Under section 123 of the AML/CTF Act, it is a criminal offence to tell a client — or anyone else — that you have filed, are filing, or are considering filing an SMR about them. Once you decide to lodge, you must not communicate this to the client. This includes indirect hints. CompliDesk's SMR workflow includes built-in tipping-off controls.
How to lodge an SMR — step by step
Document your suspicion. Record what you observed, when you first formed a suspicion, and what specific facts and circumstances gave rise to it. Be factual and specific — vague reports are less actionable for AUSTRAC investigators.
Escalate to your Compliance Officer. Your AML/CTF program should specify who is authorised to make the final decision on lodging an SMR. For most small professional services firms this is the principal.
Log into AUSTRAC Online at online.austrac.gov.au using your reporting entity credentials. Select "Lodge a report" → "Suspicious Matter Report."
Complete all required fields. Describe the suspicious matter in detail — what happened, who was involved, what amounts were concerned, and exactly what gave rise to your suspicion. Include the client's identity details and the nature of your business relationship.
Attach supporting documents if relevant — transaction records, identity documents, correspondence, or other evidence that supports your report.
Submit and record the reference number. AUSTRAC will issue a report reference number. Store this in your compliance records for 7 years alongside a copy of the report.
Part 2 — Threshold Transaction Reports (TTRs)
What triggers a TTR?
A TTR must be lodged when your firm sends, receives, or is involved in a cash transaction of $10,000 or more — or foreign currency equivalent. This is a strict liability obligation: if the cash threshold is met, you must report. There is no discretion.
What counts as "cash"? Physical currency — notes and coins. Electronic funds transfers, cheques, and credit card payments do not trigger TTR obligations even if they exceed $10,000. However, they may still trigger SMR obligations if they appear suspicious.
TTR deadline
TTRs must be lodged with AUSTRAC within 10 business days of the transaction occurring.
When do accountants typically encounter TTR obligations?
Most professional services firms rarely handle cash directly. However, TTR obligations may arise when:
- You receive a cash payment from a client for services exceeding $10,000
- You hold client funds in a trust account and receive cash above the threshold
- You assist a client with a transaction involving cash above the threshold
If your firm doesn't routinely handle significant cash, TTR obligations are unlikely to arise frequently. But you should have a process in place to identify when they do.
Structuring — the most important TTR issue for Tranche 2 reporting entities
It is a criminal offence under the AML/CTF Act to structure transactions to avoid the $10,000 TTR reporting threshold — for example, by splitting a $12,000 cash payment into two $6,000 payments. This is called "structuring" and it applies both to your own firm and to advice you give clients.
If a client asks you to help them structure cash transactions below $10,000 to avoid reporting, this is itself a serious red flag requiring an SMR — and potentially criminal liability for you if you assist.
How to lodge a TTR
The process is similar to an SMR: log into AUSTRAC Online, select "Lodge a report" → "Threshold Transaction Report," complete the required fields including the transaction amount, parties involved, and the nature of the transaction, and submit. Store the reference number in your compliance records.
Part 3 — International Funds Transfer Instructions (IFTIs)
A third report type — International Funds Transfer Instructions — applies when your firm sends or receives instructions to transfer funds internationally. IFTIs must be lodged within 10 business days of sending or receiving the instruction. Most small professional services firms will not frequently trigger IFTI obligations, but firms serving clients with offshore structures or international transactions should be aware of this requirement.
What AUSTRAC looks for in SMR/TTR compliance
When AUSTRAC audits your firm's reporting compliance, they typically check:
- Whether you have a documented process for identifying reportable matters
- Whether SMRs were lodged promptly after suspicion was formed
- The quality and specificity of your SMR descriptions
- Whether tipping-off controls are in place
- Whether TTR records align with any cash transactions in your records
- Whether staff understand their reporting obligations
CompliDesk includes guided SMR and TTR workflows.
Built-in tipping-off controls, AUSTRAC-format reports, and a 7-year audit trail for every lodgement. Sign up free for free signup.
Sign up free todayRelated: Complete Tranche 2 guide · AML red flags for Tranche 2 reporting entities · AUSTRAC enrolment checklist