Reporting Obligations

As a Tranche 2 reporting entity, you are legally required to submit certain reports to AUSTRAC. Timely and accurate reporting is one of your most important obligations — the information you provide helps AUSTRAC and law enforcement detect and disrupt money laundering and terrorism financing.

Verifia assists with drafting reports, tracking deadlines, and maintaining records of all submissions.

Suspicious Matter Reports (SMR)

When to file

You must file an SMR whenever you form a suspicion on reasonable grounds that a customer, transaction, or attempted transaction may be related to:

• Money laundering — the process of making illegally obtained money appear legitimate
• Terrorism financing — providing or collecting funds for the purpose of terrorist acts
• An offence against a Commonwealth, State, or Territory law punishable by imprisonment of 12 months or more
• Proceeds of crime — dealing with property that is the proceeds of an indictable offence
• Tax evasion — where the conduct relates to an offence under a taxation law

A suspicion does not require certainty or proof. It is a lower threshold than belief or knowledge. If something does not seem right based on what you know about the customer, their business, or the transaction, you should seriously consider whether to report. It is always better to report and let AUSTRAC assess the matter than to dismiss a genuine concern.

Forming a suspicion

Common triggers for suspicion include:

• The transaction has no apparent economic or legal purpose
• The customer's explanation is implausible or inconsistent
• The customer is reluctant to provide identity documents or source of funds
• The transaction is structured in an unusually complex way
• The customer's profile or behaviour does not match the transaction
• Information from screening (sanctions, PEP, adverse media) raises concerns
• The transaction pattern is inconsistent with what you know about the customer

Deadlines

The deadline runs from when the suspicion is formed, not from when the transaction occurred. You should file as soon as practicable — do not wait until the deadline is about to expire.

What to include

An SMR should contain:

• Details of the customer(s) involved (as known to you)
• Description of the transaction, activity, or matter that gave rise to the suspicion
• The reason you formed the suspicion — what specifically concerned you
• Any supporting evidence or documentation
• The date the suspicion was formed

You are not required to investigate or prove the matter — that is AUSTRAC's role. Report what you know and what concerned you.

Tipping-off prohibition

It is a criminal offence (punishable by imprisonment) to disclose to any person — including the customer, their representatives, or colleagues who do not need to know — that an SMR has been, is being, or will be filed.

Verifia enforces automatic confidentiality controls:

• SMR-related information is restricted to authorised personnel only (Compliance Officer and designated approvers)
• The system prevents accidental disclosure through role-based access controls
• Audit logs track all access to SMR data
• SMR records are stored separately from general customer files

Legal Professional Privilege (Legal Profession only)

If you are a legal practitioner, you must complete a Legal Professional Privilege (LPP) assessment before submitting any report to AUSTRAC. Information protected by LPP cannot be included in reports. However, LPP does not remove your obligation to file the report — it only limits what information can be included.

See the Legal Profession industry guide for the detailed LPP workflow.

Threshold Transaction Reports (TTR)

When to file

You must file a TTR when a customer conducts a transaction involving $10,000 or more in physical currency — that is, notes and coins. Electronic transfers, cheques, and card payments do not trigger TTR obligations.

For dealers in precious metals, stones and jewellery, the $10,000 threshold also applies to:

• Virtual assets (cryptocurrency) used as payment
• Linked transactions — multiple related transactions that together reach the $10,000 threshold

See the Precious Metals industry guide for details on linked transaction detection.

Deadline

10 business days from the date of the transaction.

What to include

A TTR should contain:

• Customer identification details
• Transaction amount, currency, and denomination breakdown
• Date and nature of the transaction
• Method of payment (notes, coins, or combination)
• Any other relevant details about the transaction

TTR does not replace SMR

Filing a TTR does not remove the obligation to file an SMR if you also form a suspicion about the transaction. A large cash transaction may require both a TTR (because it exceeds $10,000) and an SMR (because the circumstances are suspicious). These are independent obligations.

Annual Compliance Report

When to file

You must submit an annual compliance report to AUSTRAC. The first report for Tranche 2 entities will cover the period from 1 July 2026 (when obligations commence) to 31 December 2026.

What to include

Your annual report should cover:

• Summary of your AML/CTF program and any changes made during the reporting period
• Key compliance activities undertaken
• Number and nature of reports filed (SMRs, TTRs)
• Training activities completed
• Risk assessment reviews conducted
• Any material compliance issues, incidents, or near-misses
• Actions taken to address deficiencies

Verifia auto-generates a draft annual compliance report using data from your compliance activities throughout the year. You review and supplement the draft before submission.

Cross-Border Movement (CBM) Reports

If you become aware of the cross-border physical movement of currency or bearer negotiable instruments (such as cheques, promissory notes, or money orders) valued at AUD $10,000 or more, you may be required to submit a CBM report.

This is most relevant for:

• Accountants who may facilitate international financial arrangements
• Legal practitioners who may handle cross-border settlements or trust distributions
• Precious metals dealers dealing in internationally sourced goods

How Verifia helps with reporting