The idea of filing a report to a government financial intelligence agency can feel intimidating. Here's what it actually involves.

SMR means Suspicious Matter Report

If you form a genuine, reasonable suspicion that a transaction or client activity might be connected to money laundering, terrorism financing, or other criminal activity, you file an SMR with AUSTRAC.

When exactly do I need to file one?

There's no fixed checklist โ€” it's a judgement call based on what you know. Some patterns that might trigger genuine suspicion: a client can't explain where a large sum of money came from, wants to structure a transaction in a way that seems designed to dodge reporting thresholds, or gives you a story that just doesn't add up given everything else you know about them.

Most red flags get explained through normal conversation and never escalate to an actual report.

How fast do I need to file it?

As soon as practicable โ€” within 24 hours if it's terrorism-related, or 3 business days for other suspicious matters.

Can I tell the client I've filed one?

No โ€” this is called "tipping off," and it's a criminal offence. You can still ask a client normal questions (like where funds came from) as part of routine due diligence; you just can't tell them you've suspected them of anything or that you've reported them.

What happens after I file it?

AUSTRAC receives it and may use it as part of a broader intelligence picture โ€” you typically won't hear back on any individual report, and that's normal. You're not expected to investigate further yourself once you've reported it.

Making this less stressful

CompliDesk walks you through exactly what information an SMR needs and helps you document your reasoning clearly โ€” so if you're ever asked later why you made the call you did, it's all recorded properly.

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Frequently Asked Questions

What is the difference between Tranche 1 and Tranche 2 under Australia's AML/CTF Act?
Tranche 1 (passed in 2006) applied only to the financial services, gambling, and bullion sectors. Tranche 2 extends these anti-money laundering and counter-terrorism financing (AML/CTF) obligations to designated non-financial businesses and professions (DNFBPs), including lawyers, accountants, real estate agents, conveyancers, trust and company service providers, and precious metals/stones dealers.
Do all lawyers, accountants and real estate agents need to register with AUSTRAC?
No, only those who provide 'designated services' as defined in Schedule 1 of the AML/CTF Act. For example, a litigator who only represents clients in court is generally not captured, whereas a lawyer who assists with property transactions, company formations, or managing client trust accounts is. Similarly, accountants providing tax advice or basic bookkeeping are not captured unless they manage client funds, set up companies, or act as trustees.
What is the AUSTRAC enrolment deadline for Tranche 2 entities?
Under the transitional arrangements, Tranche 2 entities were required to enrol with AUSTRAC by 29 July 2026, following the official commencement of the reforms on 31 March 2026.

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